Closure of Jefferson Proving Ground, Indiana, and Realignment to Yuma

Home , Camp Laguna, Chocolate Mountains, Gypsy (software), Jefferson Proving Ground, Laguna Army Airfield

___ -

CLOSURE OF JEFFERSON PROVING GROUND INDIANA AND REALIGNMENT TO YUMA PROVING GROUND ARIZONA

'J.fI..,o. Pre.1. VOLUME 1 OF 2 *YE=. GI.".] Pre.1. TEXT G,...d Final ENVIRONMENTAL IMPACT . I STATEMENT September 1991 - . CLOSURE OF JEFFERSON PROVING GROUND, INDIANA AND REALIGNMENT TO WMA PROVING GROUND, ARIZONA

Prepared by: Reviewed by: Louisville District U.S. Amy U.S. Army Corps of Engineers Materiel Command

yy\C .- David E. Peixotto William 8. McCrath Colonel, Corps of Engineers Major General, US. Army Commander Chief of Staff

Recommended for Approval by: Department of the Army Office of the Chief of Staff

William A. Stofft Mabr General, General Staff Director of Management

Approved by: Office of the Secretary of the Amy

& 6,D& Lewis D. Walker Deputy Assistant Secretary of the Amy (Environment, Safety and Occupational Health) FINAL ENVIRONMENTAL IMPACT STATEMENT

CLOSURE OF JEFFERSON PROVING GROUND, INDlANA AND REALlGNMENT TO Wh4A PROVING GROUND, ARIZONA

LEAD AGENCY: Department of the Army, U.S.Amy Materiel Command (AMC);

TITLE OFTHE PROPOSED ACTION Closure of Jefferson Proving Ground, Indiana and Realignment to Yuma Proving Ground, Arizona

AFFECTED JURISDICTION: Jefferson Proving Ground: Jefferson, Jennings and 1Zipk-y Counties, Indiana. Yuma Proving Ground: Yuma and La Paz Counties, Arizona

PREPARED BY David E. Peixotto, Colonel, Corps of Engineers, Commander, US. Army Corps of Engineers, Louisville District, P.O. Box 59, Louisville, KY 40201-0059

REVIEWED BY: William 8. McCrath, Major General, Chief of Staff, US. Army Matericl Command

RECOMMENDED FOR APPROVAL BY Williim A. Stofft, Major General, General Staff, Director of Management, Office of the Chief of Staff, Department of the Army

APPROVED BY Mr. Lewis D. Walker,, Deputy Assistant Secretary of the Ammy (Environment, Safety, and Occupational Health)

ABSTRACT The action evaluated in this Final Environmental Impact Statement includes the closure of Jefferson Proving Ground (JPG),Indiana, and realignment of personnel and equipment to Yuma Proving Ground (YE),Arizona. The impacts associated with the alternative methods of implementing the realignment action to YPG are analyzed. The closure and realignment action is in accordance with the Defense Authorimtion Amendments and Base Closure and Realignment Act, and the Defense Secretary's Commission on Base Realignment and Closure. This EIS considers the effects of the planned action on the natural and human environments at JPG and YPG. The discontinuation of testing activities is considered to be a beneficial environmental impact at JPG because no new contamination caused by firing additional ordnance will occur. The closure of JFC will not change the potential for existing UXO contamination. However, the extent and level of existing contamination are unknown. [Significant adverse economic impacts due to closure of JFG are expected2Implementation of the realignment of JPG to the central Kofa Range at YPG will result in potential adverse impacts to vegetation, wildlife and cultural resources. Surveys will be performed prior to construction and appropriate mitigation measures will be developed where necessary. A recent noise study has determined that there will be no significant impact due to the mission transfer from JPG to WG. Beneficial impacts on the regional economy are expected at YPG due to the realignment action.

NO Action will be taken until 30 days from the FElS filing with the Environnicntal Protection Agency and publication of the Notice of Availability in the Federal Rth'' mlrr. Following the 30 day waiting period, on or about September 24, a Record of Deci&on will be filed with the Army Environmental Office. EXECUTIVE SUMMARY

Introduction

The Base Realignment and Closure Conimission (The Commission) was c*stiildislicxl by thc Stvrt%iry of Defense on May 3, 1988. Its purpose was to recommend rcalignnient iind c,losiirl, of milit.iry I~,ISC~S within the United States, its commonwealths, territories, and possessions. 'l'lir I >vfcwsr Aii~Ii(ii.i/.,itioii Amendments and Base Closure and Realignment Act, Public LAW 100-.52h, dntrd Ortolwr 24, IOXH, directed 145 realignments and closures (Appendix A). Based on this dircction, tliv C'oniniission presented its recommendations to the Secretary of Defense on December 29, 11)H8.

The Law requires the closure of the US.Army Jefferson Proving Ground (JlC), which is Iocntcd six miles north of Madison, Indiana. Its mission of ammunition acceptance testing lor tho Army is !(I hc relocated to the US.Army Yuma Proving Ground (YE), Yuma, Arizona.

The closure of JPC means the discontinuation of operations in preparation for movcmrnt to aiioth~r site. This closure activity will take place in a phased manner from 1991 to 1005. 'I'ht* hiis(, rva1it;iiintmt and closure process is a dynamic process that will rquire continuoits refiiienivnt to iiw*lI hc Ariny's changing needs and circumstances.

The closure alternatives considered in this Environmental lmpnct StaLement (1%) includc tlic No Action Alternative and the Proposed Action. Although P.L. 100-526 cxcmpts tlic decision to cIos(~Ironi environmental analysis, the No Action Alternative has been established as a benchmark iipiinst which the proposed closure action may be compared. This proposed action is the closiire of JI'C: iind thc realignment of the munitions production acceptance testing mission to YPG. Several realignment implementation alternatives at YPG were considered and some were eliminated from further consideration due to feasibility, cost, or environmental concerns. These included locating the proposcd facilities on the West Arm of YPG, and a phasing alternative. Other implementation alternatives wcw considered including the realignment of JI'G activities to the East Arm of YPG. The proposed realignment action is to intensify the use of the central Kofa Range.

The JPC analysis focuses upon the cessation of operations at JPG. Some potential rciisr options arc described but not analyzed. The YM; analysis focuses on the alternatives to iniplemrntntion of th(* realignment action. The environmental consequences of the planned closure at JIY; and impleinrii1;iticiii alternative actions at YPC are reported, as well as general means for minimizing and mitignlinl; unavoidable adverse impacts.

This EIS does not address specific actions or impacts associated with potentiiil remedinlion .ic'tivities at JPC. The Army will conduct a Remedial Investigation/Feasibility Study (RI/FS) on thr iirc'ii of JIY; in the cantonment area and clean it up. En addition, a RI/FS will be performed on any othrr area priy to releasing that property from Department of Defense (DOD)contrdl Hazardous matcriills are discussed to the extent that they affect or are affected by closure or realignment. Army rt?quireiiwntr concerning environmental compliance will be met prior to the disposal of any property. Remcdiiih. and reuse planning are interrelated processes. The Army will address the effects of spcrific rws(’ alternatives in separate analyses in accordance with the National Environmental Policy Act (NKI’A).

Closure of JF‘G and the realignment of its munitions testing activities at YPC will affect a totiil of 14 military and 407 civilian personnel positions. Three military positions and 135 civilian positions will be eliminated. Closure will require the transfer of 271 civilian personnel positions. No lnilitiiry positions will be realigned to YPG. The remaining personnel shifts include the transfer of one civilian to Fort Shafter, HI and the transfer of 11 members of the Indiana Air National Guard (INAN(;) to an as yet undesignated installation.

In addition to the transfer of personnel positions, realignment involves the construction of additional facilities and gun emplacements for direct fire, mortar and depleted uranium (DU) at the cxisting Kofa Range at YPG. There will be construction of associated ammunition handling, storage and trsting facilities as well as additional maintenance and administration facilities. A summary of new construction requirements is provided in Table S1. The estimated cost for facility construction is $82.2 million. One time expenditure estimates are $50.04 million which would result in a total realignment estimate of $132.24 million. This EIS does not address the financial data nor estimated cost savings that were considered by the Commission during the base closure and realignment decision making prows5

JPG Potential Reuse Options Discussed

Potential options for reusing surplus JPG property were identified on the basis of consultation with the key participants involved with the closure and reuse process. Options were selected by applying reuse evaluation criteria, including: compatibility with existing land use activities, conditions, policies and restrictions; compatibility with significant M~UAresources located within the boundaries of Jl’G; general market feasibility requirements and current regulatory factors or limitations. General rruse options discussed include: like-kind use, general aviation facility, regional (five county landfill), and correctional facility.

The impacts associated with reuse of JPG are not addressed in this document. The impacts will be discussed in follow-on NEPA analysis and documentation. Reuse will be studied by the JPG Regional Development Board in conjunction with the Army and Office of Economic Adjustment. Table 5-1. Summary of new construction required for Proposed Action at YE.

Facility AM (in square M) -

1. Direct Fire Ran% Gun Positions Bsrricade 12,000 Communlcatlonr Building 400 Data Collection Building -400 12.800

2. Artillery and Mortar Rrina Position Firing Positions Barricade Culvert Bunkers 800 Data Collection Building -800 31.600

3. Armament Operations Center Administrative Area 23,000 Tcchnical Area 49,000

4. Su~portand Maintenance Facility Test Maintenance Facility and Addition to 3490 76,000 One Company Fire Station 5.871,~ Lougred Gun Tube Storage lo-o& 91,871

5. Ammunition Reparation Facility Assembly Plant 43,170 €OD Disassembly Bullding 9,200 inert Storage Complex D 57,370

6. Ammunition Handling Facility Ammo Swdllrnce Building 14,741 Ammo Shipping and Receiving Building 2.108 &Bay Storage Cubicle 2 17,649

7. Ammunition Storapc Fulllty Insert Storage Building 41,200 Oval Arch Magazine 40.050 Depleted Uranium Storage 86,250

8. Vibration Test Faciilty

9. Ammunition Test Faciliy Cator Mine Test Building 5.600

10. utility ~ervim Well House (3 each) 360

11. Communication Services Expand Building 3659

5-3 Major Findings and Conclusions

Impacts associated with the JKclosure action are summarized in Table S-2. The discontinilation oi testing activities is generally considered to be beneficial rather than a ncgnlive environmrntal inipict at JPG because no new contamination caused by the firing of additional ordnance will occur. The closure of JPC will not change the potential for contamination from existing UXO. 'l'hv lack of comprehensive data on present levels of soil contamination, groundwater ctintaiiiiniition iiiid siir1,ic.r water quality makes the determination of impact difficult. Past usage and disposal or Ii~i~~~ir~loiis materials is expected to have long-term impacts.

Upon closure, soil erosion and sedimentation will continue to occur. Surface watw qii,ility of Harberts Creek will improve after closure due to decreased discharges from the sewage treatment plant. Wildlife and vegetation will benefit from the closure action. Select species may be affected by cmsation of prescribed burning, yet the impact is expected to be minor.

Air pollution emissions will be significantly reduced upon closure. Since JPC is within J. region designated in compliance with state and Federal air quality standards, a minor beneficial impact is expected. Noise generated duringthe testing operations will end, resulting in a positivc impiict. Noise generated under current conditions is primarily kept within the boundaries of the facility. Therefore, the reduction in noise produced is not considered significant. Visual and aesthetic qualities are benefitted by the elimination of testing. However, these benefits are minimized by controlled access to the installation.

Socioeconomic impacts due to closure will be significant (IWR 1989). Approximately 421 paid positions will be eliminated, causing an estimated regional population decrease of 1,234 people. 'This will result in a total decrease in regional sales volume of approximately $47 million, a decrease in regional employment of 940 person-years, and a decrease in regional income of approximately $17 million.

The closure of JPG will not impact the cultural resources located within JPC. The closing of the post could have a positive impact on the extant archeological sites because ground disturbance would decrease. :A detailed assessment of the integrity of all the historical structures will be prepared in follow-on reuse NEPA analysis and documentation3 .

During the process of mission realignment and deactivation of the JPC, a short-term increase in solid waste generation and disposal requirements will occur. Solid waste disposal will dcrrcasc sipiific,intly after closure. It is unknown whether an on-post or off-post disposal site will br ustui. Signific.int

5-4 Table 5-2. Summary of potential impacts asxxiatcd with closure ofthe JeffersonProving Ground

-~~~~~~~ ~ ~~~~ ~ frdion Rd-n FAcroR 1.4 I.! Clim.1e

1.4 1.2 T-mphy

J.4.1.3 Crology kMinml RRm-

].4.1.4 pslcontology

1.4.1.5 Soils

1.4.1.61 Groundwaln

1.4.1.6.2 sur(.m Water

1.4.1.7 Aquatic Resow

1.4.1.8.1 WUdlUcRmurcm

J.4.1.8.2 vga.tion

].4.I.e.l-2 Thmtmcd khdangscd Spdn

1.4.1.83 WcUlnds

1.42 Air Quality

1.4.3 Noise

1.4.4.1 Vvud L AslhelicQudIti6

1.4.4.2 Native Ama(cu, Con-

1.4.4.3 Culhlrd Icsnrrca

1.4.4.4 ZoninghPoUticll Dound.ris

J.4.4.5.l P+Ih

1.4.4.5.3 Reglorul Emnomic Adlvity

].4.45.&6 bmmunly FxilUs

J.4.4.5.7 hbllcS.fcty

1.4.4.5.8 Tdk&T-phtion

1.4.4.5.9 Wadnulls Dispcd

J.4.4.5.10 SDUd Wulehpoul

J.4.4.5.11 Rrcmtlon

1.1.4.5.12 UUUtia System

1.4.4.6 Haurdnu MilsiJs

s-5 impact to area landfills, if used, is not expected. Private sanitary refuse contractors would hcnrfit during the closure period, yet long term impacts on JPG's contractors would be negative.

Impacts associated with the various implementation alternatives at YPG are summarizcd in Table 53. Implementation of the proposed action will result in potential adverse impacts to vegetation and wildlife associated with the construction of new facilities as well as increased use of the Kofa Range. Realignment to the Kofa Range has the potential to create significant adverse impacts to cultural resources. The implementation of the proposed action also will result in potential adverse impacts to aesthetic values. There also will be increased air pollutant emissions associated with testing and construction. Kofa Range ordnance contamination will increase as will adverse traffic impacts and impacts assodated with increased transportation of munitions. lncreased noise from the realignment is not expeaed to have a significant impact on the Kofa National Wildlife Refuge. Beneficial economic impacts will arise from the increased employment at YT'G as well as the increased expcnditurc for construction of facilities.

YPG realignment alternatives involving the use of the East Arm have the potential to create significant adverse impacts to ~lturaland biological resources and will also increase ordnance contamination in areas relatively free of contamination. There is also a potential of socioeconomic impacts associated with increased development within small rural communities east of Yuma.

Implementation alternatives on the West Arm of YPG are not considered feasible since they would interfere with other ongoing missions at YPG. Potentially significant impacts to cultural resources and biological resources would also be expected. Time phasing the alternatives involving YPG would have essentially the same level of impacts as the proposed action. This alternative was not further considered feasible since with it, realignment could not be completed within the mandated time frame.

Areas of Public Concern

The major areas of public Concern identified at the JPG scoping meeting relate to the amount of unexploded ordnance and its cleanup, other hazardous materials and wastes, the potential for reuse, and the potential presence of'threatened and endangered species. Major concerns identified at YPG include potential archeological impacts, potential impacts to the neighboring wildlife refuges and the increased local traffic burden.

The Amy will retain JPG property for an undetermined amount of time. The Army intends b implement a sampling program of selected sites and all streams to determine if contamination ISpresenk in concentrations that would be hazaFdous to the public or the environment and to conduct a remedial.

S-6 Y.4.1.4 Plleontology A A A A A A

Y.4.1.5 Soils A A A A 0 0

Y.4.1.6.1 Gmund Water 0 0 0 0 0 0

Y.4.1.62 Surface Water A A A A 0 0

Y.4.1.7 Aquatic Heom 0 0 0 0 0 0

Y.4.1.8.1 Wildwe Resources S S S S A A

Y.1.1.82 vegetation S S S S A A

Y.4.1.8.1-2 Threatened & Endangered spda 0 0 0 0 0 a

Y.4.1.8.3 Wetlands 0 0 0 0 0 0

Y.4.1 Air Qudiiy A A A A A A

Y.43 Noise A A A A A A

Y.4.4.1 Vhd& Anhetic Vdua A A A A A A

Y4.42 Native A-cmVdun A A A A A A

YP.43 CultdResourcn S S S S S 5

Y.4.4.4 zc&g k Politid Bounduio 0 0 a 0 0 0

Y.4.4.5.1 Populrtio. 0 0 0 0 0 0

Y.4.452 RegidEconomic Activity B B B 8 B II

Y.4.4.537 Communiiy Fadlitia A A A A a 0

Y.4.4.5.8 Traffic & Tnnspabtion A A A A A A

Y.4.45.9 w.stewatcl bpmal A A A A A A

Y.4.4.5.10 Mid Waaa Dlrp.1 A A A A A A

Y.4.4.5.11 R-ation A A A A A A

Y.4.4.6 Hazardour MaW S S A A A A

Lgend . No Impact 0 Bmeficirl Impact B AdvenrlNoI Signifion1Impact A Significant/PotenliaUy Sigdiont hpxt S

s-7 investigation/feasibility study (RI/FS)in the cantonment area south of the firing line and clean 11 up The Army will also comply with its regulatory obligations which include Resource Conservation and Recovery Act (RCRA) permitted activities for the open burning and open detonation units, undergmuna storage tanks and the Nuclear Regulatory Commission (NRC) licensed depleted uranium WU) impcY field. The field work of the RI/FS of the cantonment area is expected to begin in October 1991 and bp completed by 1993.

Another area of public concern is the potential occurrence of threatened and cndanjyrrd sptxh. Impacts to these species cannot be predicted with certainty but generally are considered h(wcfici;il (iuc to cessation of testing activities at JPG. Consultation and coordination between the Jl’C staff, the LJtiitcad States Fish and Wildlife Service and the Indiana Department of Natural Resources is currently under way for surveying the JPG for potential endangered species, including vegetation, the Indiana hat and the bobcat. The results of these surveys will aid in future planning for timbering activities and controlled. The Army will prepare a Natural Resources Management Plan that will address threatciied and endangered species, species of concern, game management, wetlands and other resources at JI’C;. This plan will comply with 32 CFR 265 and all other applicable laws. Timber management will be a addressed in the Natural Resources Plan. A sedimentation and erosion control plan will also bw prepared and implementec& These measures will minimize adverse impacts associated with ~Iicissiws described above.

Construction of facilities at YEhas the potential to impact cultural resources as well as scrisitir biological resources. Surveys of project sites will be conducted prior to construction and appropriatr mitigation measures will be formulated if cultural resources or sensitive species arc found. A recent noise study prepared for YE,determined that noise for the existing and proposed JPC range operations are compatible with the existing land uses at YPG. The increased noise from base realignment is not expected to have significant impact on wildlife. No additional noise impacts off the installatinns are identified.

There will be increased shipment of munitions to YPG due to the increased firing mission at the base. This will increase the potential for roadway accidents involving trucks carrying munilions. Increased car pooling or van use will reduce potential adverse impacts due to increased traffic.

Relationship of Proposed Action to Environmental PermitdRequiremen ts

Compliance with applicable Federal environmental acts and executive orders (Table S-4) is currimtly in progress. Coordination between the Indiana Department of Natural Resources and JI’C is undcrway with plans for endangered species surveys for vegetation, the Indiana bat and the bobcat Coordiniilion with the U.S.Fish and Wildlife Service also is currently underway for both YI’C and JPC.~‘hc-sc lions

s-8 will comply with the Endangered Species Act. All proposed use areas at the YPG will be surveyed for vegetation and wildlife resources once detailed plans are available.

A cultural resources Programmatic Agreement (Appendix B) has been signed by the Department of , the Army, the Advisory Council on Historic Preservation, and the National Conference of State Historic I Preservation Officers. In addition, individual Memorandums of Agreement (MOA) are being developed , for both JPG and YPG and their respective State Historic Preservation Officers, the Advisory Council on Historic Preservation, and the Department of the Army. These agreements are coordinated in accordance with the Amy's responsibility under Sections 106 and 110 (fl of the National 1 listoric Preservation Act (NHPA). Consultation with the Indiana and Arizona State Historic Preservation Offices is on-going to assure that cultural resources are protected, maintained and secured.

Prior to implementation of the proposed closure of JPG, a NRC approved decommissioning plan for DU remediation will be prepared. The NRC license currently held by YFG also will require modification due to the DU testing program being realigned from JPG.

Due to the realignment to YPG, generation of. hazardous waste, including propellants, explosives and pyrotechnics, will substantially increase. Therefore, YPG's RCRA Part B permit for open burning of propellants and open detonation of explosives will have to be submitted to the State of Arizona and EPA Region LX for modification. JPG will fulfill its regulatory obligation to close the open burning and open detonation units according to RCRA requirements. In addition, JPG will comply with EPA and state RCRA requirements for the closure of underground storage tanks (UST's).

The objective of this EIS is to comply with the National Environmental Policy Act of 1969 (NEPA) in accordance with the Base Closure and Realignment Act. In addition, all phases of the EIS will be properly submitted and announcement and occurrence of all opportunities for public and agency participation will be completed in accordance with NJZPA.

s-9 Table S4. Compliance with environmental statutes.

Federal Policies ComDliance

Atomic Energy Act Ongoing

Clean Air Act (CAA), as amended Ongoing

Clean Water Act (CWA), as amended Ongoing

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorizaton Act (SARA) Ongoing

Endangered Species Act of 1973, as amended Ongoing

Federal Insecticide, Fungicide, and Rodenticide Act (Fa) Ongoing National Environmental Policy Act of 1969 (NEPA) Ongoing

National Historic Reservation Act of 1966, as amended (MF'A) Ongoing

Resource Conservation and Recovery Act (RCRA) Ongoing

Toxic Substances Control Act CECA) Ongoing

EXECUTIVE ORDERS Floodplain Management (EO.11988) Complete

Protection of Wetlands (E.O. 11990) Complete

Protection and Enhancement of the Cultural Environment, 1971 (E.0.11593) Ongoing

Note: Ongoing = some requirements of the regulations remain to be met by subsequent actions at JPG and YPG. Complete = having met all statutory requirements for this action.

s- 10 TABLE OF CONTENTS

EXECUTIVESUMMARY ...... s- i LISTOFTABLES ...... vii LISTOFFIGURES ...... ix LIST OF ACRONYMS AND ABBREVIATIONS ...... xi

CHAPTER 1 - PURPOSE OF AND NEED FOR THE ACTION 1.0 INTRODUCTION ...... 1-1 1. 1 PURPOSE AND NEED FOR THE ACTION ...... 1-1 1.2 REGULATORY AUTHORlTY ...... 1-2 CHAPTER 2 - ALTERNATIVES CONSIDERED 2.0 INTRODUCTION ...... 2-1 2.1 NO ACTION ALTERNATIVE ...... 2-1 2.2 THE PROPOSED ACTION ...... 2-6 2.2.1 Workforce Position Determinations ...... 2-7 2.2.2 The Closure of Jpc ...... 2-7 2.2.3 JPG Caretaker Status ...... 2.1) 2.2.4 Other Considerations of the Proposed Action ...... 2.10 2.3 REUSE POTENTIAL OF JEFFERSON PROVING GROUND ...... 2-12 2.3.1 JPG Reuse Planning ...... 2-12 2.3.2 JPG Property Reuse Potential Scenarios ...... 2-13 2.3.3 Alternatives Considered Potentially Viable ...... 2-15 2.4 YUMA PROVING GROUND IMPLEMENTATION ALTERNATIVES ...... 2-18 2.4.1 Proposed Action ...... ' 2-18 2.4.1.1 General Desaiption of Activities ...... 2-18 2.4.1.2 New Facilities Required ...... 2-19 2.4.1.3 Addition to Restricted Airspace ...... 2.22 2.4.2 Other Alternatives Considered ...... 2.22 2.4.2.1 Realignment of JPG Activities to East Arm .... 2.22 2.4.2.2 Reduced Realignment of JPG Activities to East Arm 2 .25 2.4.3 Alternatives considered but Eliminated ...... 2.25 2.4.3.1 Full Realignment of JPG Activities to West Arm 2 .25 2.4.3.2 Partial Realignment of JPG Activities to West Am 2 .25 2.4.3.3 No New Facilities ...... 2.26 2.4.3.4 Phasing ...... 2.26

CHAPTER 3 - AFFECTED ENVIRONMENT 3.0 INTRODUCTION ...... 3-1

SECTION J - JEFFERSON PROVING GROUND J.3.1 NATURAL ENVIRONMENT ...... 3-1 1.3.1.1 Climate ...... 3-1 J.3.1.2 Topography ...... 3-2 J.3.1.3 Geology and Mineral Resources ...... 3-2

i TABLE OF CONTENTS (continued)

1.3.1.4 Paleontology ...... 3-H J.3.1.5 Soils ...... 3-8 1.3.1.5.1 Cobbsfork-Avonburg Soil Association ...... 3-H J.3.1.5.2 Cincinna ti-Rossmoyne-Hickory Soil Associa tion ...... 3-H 1.3.1.5.3 Combined Soil Types ...... 3- 12 1.3.1.6 Water Resources ...... 3- 12 J.3.1.6.1 Groundwater ...... 3- 12 J.3.1.6.2 Surface Water ...... 3- I? 1.3.1.7 Aquatic Resources ...... 3- 17 J.3.1.8 Terrestrial Ecology ...... 3- 1x 1.3.7.8.1 Wildlife ...... 3 .1') J.3.1.8.2 Vegetation ...... 3 . 24 13.1.9 Wetlands ...... 3 .31 j.3.2 AIR'QUALITY ...... 3 .33 J.3.2.1 Ambient Air Quality Standards ...... 3 .34 J.3.2.2 Present Compliance Status ...... 3 34 J.3.2.2.1 Attainment at Air Quality Monitoring Sites ...... 3 . 05 J.3.2.3 Air Control Permits ...... 3 .36 J.3.3 NOISE FACTORS ...... 3 . 30 J.3.4 HUMAN ENVIRONMENT ...... 3 41 1.3.4.1 Visual and Aesthetic Resources ...... 3 .41 1.3.4.2 Native American Values ...... 3 . 42 J.3.4.3 Archaeological/Cultural/Historical Resources ...... 3 .42 J.3.4.3.1 Prehistoric Cultural Resources ...... 3 .44 1.3.4.3.2 Historic Cultural Resources of JPG ...... 3 . 44 1.3.4.3.3 Archeological Site Potential ...... 3 .46 1.3.4.4 Zoning and Political Boundaries ...... 3 . 48 J.3.4.5 Socioeconomic Characteristics ...... 3 . 52 J.3.4.5.1 Installation Overview ...... 3 .52 J.3.4.5.2 Population ...... 3 .53 J.3.4.5.3 Landuse ...... 3 . 53 J.3.4.5.4 Regional Economic Activity ...... 3 .60 J3.4.55 Housing ...... 3-60 J.3.4.5.6 Schools ...... 3 .60 J.3.4.5.7 Health Care ...... 3 . 61 J.3.4.5.8 Public Safety ...... 3 .61 1.3.4.5.9 Traffic and Transportation ...... 3 .63 J.3.4.5.10 Wastewater Disposal ...... 3 .65 1.3.4.5.11 Solid Waste Disposal ...... 3 . 66 J3.4.5.12 Recreation ...... 3 . 66 J.3.4.5.13 Utility Systems ...... 3 . 6X J.3.4.6 Hazardous Materials/Wastes ...... 3 . (1')

ii TABLE OF CONTENTS (continued)

SECTION Y .YUMA PROVlNG GROUND Y.3.1 NATURAL ENVIRONMENT ...... 3.70 Y.3.1.1 Climate ...... 3~70 Y.3.1.2 Topography ...... 3 . 7') Y.3.1.3 Geology and Mineral Resources ...... 3.70 Y.3.1.3.1 Geology ...... 3 . 7') Y.3.1.3.2 Minerals ...... 3. nz Y.3.1.4 Paleontology ...... 0 . n:\ Y.3.1.5 Soils ...... 3.83 Y.3.1.6 Water Resources ...... 0.83 Y.3.1.6.1 Groundwater ...... 3.n3 Y.3.1.6.2 Surface Water ...... 3.87 Y.3.1.7 Aquatic Ecology ...... 3. u!, Y.3.1.8 Terrestrial Ecology ...... 3. U'j Y.3.1.8.1 Description of General Biological Resources at YPG ...... 3~ no Y.3.1.8.2 Description of Biological Resources of the Various Planning Regions at MJG ...... 3.97 Y.3.2 AIR QUALlTY ...... 3 . 100 Y.3.3 NOISE FACTORS ...... 3 .110

Y.3.4 HUMAN ENVIRONMENT ...... 3 ~ 111 Y.3.4.1 Visual and Aesthetic Qualities ...... 3- 111 Y.3.4.2 Native American Values ...... 3-112 Y.3.4.3 Archaeological/Cultural/Historic Resources ...... 3- 112 Y.3.4.3.1 Cultural History ...... 3-112 Y.3.4.3.2 Previous Research ...... 3.116 Y.3.4.4 Zoning and Political Boundaries ...... 3 . 120 Y.3.4.5 Socioeconomic Characteristics ...... 3- 122 Y.3.4.5.1 Installation and Regional Overview ...... 3- 122 Y.3.4.5.2 On Post-Population ...... 3 .124 Y.3.4.5.3 LandUse ...... 3- 124 Y.3.4.5.4 Regional Economic Activity ...... 3- 127 Y.3.4.5.5 Housing ...... 3 . 130 Y.3.4.5.6 Schools ...... 3- 132 Y.3.4.5.7 Health Care ...... 3 .132 Y.3.4.5.8 Public Safety ...... 3 .136 Y.3.4.5.9 Traffic and Transportation ...... 3 .138 Y.3.4.5.10 Wastewater Disposal ...... 3 .141 Y.3.4.5.11 Solid Waste Disposal ...... 3 .141 Y.3.4.5.12Recreation ...... 3 .141 Y.3.4.5.13 Utilities ...... 3 . 140

iii TABLE OF CONTENTS (continued)

Y.3.4.6 Hazardous Materials/Wastes ...... 3 . 140 Y.3.4.6.1 Hazardous Materials Associated with the Various Structures ...... 3 . i46 Y.3.4.6.2 Hazardous Materials Associated with the Land . . 3- 147 Y.3.4.6.3 Fuel Storage ...... 3- 147 Y.3.4.6.4 Hazardous Materials Associated with Projectiles . 3 . 150

CHAPTER 4 - ENVIRONMENTAL AND SOCIOECONOMIC CONSEQUENCES 4.0 INTRODUCTION ...... 4-1

J . - JEFFERSON PROVING GROUND CLOSURE ACTION J.4.1 NATURAL ENVIRONMENT IMPACE ...... 4-2 1.4.1.1 Climate ...... 4-2 J.4.1.2 Topography ...... 4-2 J.4.1.3 Geology and Mineral Resources ...... 4-2 1.4.1.4 Paleontology ...... 4-2 J.4.1.5 Soils ...... 4-1 J.4.1.6 Water Resources ...... 4-3 1.4.1.6.1 Groundwater ...... 4-0 1.4.1.6.2 Surface Water ...... 4-4 1.4.1.7 Aquatic Resources ...... 4-4 J.4.1.8 Terrestrial Ecology ...... 4-5 J.4.1.8.1 Wildlife ...... 4-5 J.4.1.8.2 Vegetation ...... 4-7 J.4.1.9 Wetlands ...... 4-8 J.4.2 AIR QUALITY IMPACTS ...... 4-8 J.4.3 NOISE IMPACTS ...... 4-9 1.4.4 HUMAN ENVIRONMENT IMPACTS ...... 4~9 J.4.4.1 Visual and Aesthetic Resources ...... 4-9 J.4.4.2 Native American Concerns ...... 4-9 J.4.4.3 Archeological, Cultural and Historical Resources ...... 4.9 J.4.4.4 Zoning and Political Boundaries ...... 4-9 J.4.4.5 Socioeconomic Characteristics ...... 4.10 J.4.4.5.1 Population and Employment ...... 4.10 J.4.4.5.2 LandUse ...... 4-11 J.4.4.5.3 Regional Economic Activity ...... 4.12 J.4.4.5.4 Housing ...... 4-14 J.4.4.5.5 Schools ...... 4-15 J.4.4.5.6 Health Care ...... 4-15 J.4.4.5.7 Public Safety ...... 4.15 J.4.4.5.8 Traffic and Transportation ...... 4-16 J.4.4.5.9 Wastewater Disposal ...... 4-17 J.4.4.5.10 Solid Waste Disposal ...... 4.17 1.4.4.5.11 Recreation ...... 4.18 J.4.4.5.12 Utility Systems ...... 4.18 J.4.4.6 Hazardous Materials/Wastes ...... 4.14,

.. TABLE OF CONTENTS (continued)

Y - ENVIRONMENTAL AND SOCIOECONOMIC CONSEQUENCES OF THE KEALICNMI!N'I' '1'0 YLJMA PROVING GROUND Y.4.1 NATURAL ENVIRONMENT IMPACTS ...... 4 - 21 Y.4.1.1 Climate...... 4 - 21 Y.4.1.2 Topography ...... 4 - 21 Y.4.1.3 Geology and Mineral Resources ...... 4 - 21 Y.4.1.4 Soils ...... 4 - 22 Y.4.1.5 Paleontology ...... 4 - 23 Y.4.1.6 Water Resources ...... 4 - 23 Y.4.1.6.1 Groundwater ...... 4 - 20 Y.4.1.6.2 Surface Water ...... 4 - 23 Y.4.1.7 Aquatic Ecology ...... 4 - 24 Y.4.1.8 Terrestrial Ecology ...... 4 - 24 Y.4.1.8.1 Wildlife ...... 4 - 24 Y.4.1.8.2 Vegetation ...... 4 - 25

Y.4.1.8.3 Wetlands ...... 4 ~ 2h Y.4.2 AIR QUALITY IMPACTS ...... 4 - 26 Y.4.3 NOISE IMPACTS ...... 4 - 27 Y.4.4 HUMAN ENVIRONMENT IMPACTS ...... 4 - 30 Y.4.4.1 Visual and Aesthetic Resources ...... 4 - 30 Y.4.4.2 Native American Values ...... 4 - 30 Y.4.4.3 Archaeological/Cultural/Historical Resources ...... 4.31 Y.4.4.4 Zoning and Political Boundaries ...... 4 - 32 Y.4.4.5 Socioeconomic Characteristics ...... 4 - 33 Y.4.4.5.1 PopuIa tion ...... 4 - 33 Y.4.4.5.2 Regional Economic Activity ...... 4 - no Y.4.4.5.3 Housing ...... 4 - 30 Y.4.4.5.4 Schools ...... 4 - 36 Y.4.4.5.5 LandUse ...... 4 - 37 Y.4.4.5.6 Health Care ...... 4 - 37 Y.4.4.5.7 Public Safety ...... 4 - 37 Y.4.4.5.8 Traffic and Transportation ...... 4 - 39 Y.4.4.5.9 Wastewater Disposal ...... 4 - 40 Y.4.4.5.10 Solid Waste Disposal ...... 4 - 40 Y.4.4.5.11 Recreation ...... 4 - 40 Y .4.4.5.12 Utilities ...... 4 - 4'1 Y.4.4.6 Hazardous Materia ls/Wastes ...... 4 - 42 4.5 UNAVOIDABLE ADVERSE EFFECTS ...... 4 - 43 4.6 SHORT-TERM USES OF THE HUMAN ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVIn ...... 4 - 43 4.7 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT

OFRESOURCES ...... 4 ~ 44

V TABLE OF CONTENTS (concluded) CHATTER 5 - CONSULTATION, COORDINATION, AND REVIEW

5.1 PUBLIC INVOLVEMENT ...... 5-1~~ 5.1.1 JPGScoping Concerns ...... 5- I 5.1.2 YPG Scoping Concerns ...... 5-3 5.2 LIST OF CONTACTS ...... 5-1 5.2.1 Jefferson Proving Ground ...... S-4 5.2.2 Yuma Provinp: Ground ...... 5 - C) 5.3 COMMENTS ON DI&IFT EIS ...... 5- 11 5.4 FURTHER PUBLIC INVOLVEMENT ...... 5- 12

CHAPTER 6 - LIST OF PREPARERS 6.1 JPG ...... 6- 1 6.2 YPG ...... 6-4 CHAPTER 7 - DISTRIBUTION AND REVIEW OF DEIS 7.1 NATIONAL ...... 7- 1 7.2 JPG ...... 7-3 7.3 YPG ...... 7-5

CHAPTER8- INDEX ...... 8- 1 CHAPTER 9 - REFERENCES 9.1 JEFFERSON PROVING GROUND ...... 9-1 9.2 YUMA PROVING GROUND ...... 9-7 CHAPTER 10 - APPENDICES" Appendix A Base Closure and Realignment Act ...... A-l Appendix B Letters ...... B-1 Appendix C Cultural Resources Programmatic Agreement ...... c-1 Appendix D Comprehensive species lists for mammals, birds, reptiles and amphibians located within the JPG project area ...... D-l Appendix E List of State of Indiana Species of Concern ...... E-1 Appendix F Common vegetation species identified on JPG ...... F-1 Appendix G Timber harvest table (by species) for JPG ...... c-1 Appendix H National Ambient Air Quality Standards ...... 1-1 - 'I Appendix I JF'G Cultural Overview ...... 1-1 Appendix J JPG Enhanced Preliminary Assessment Findings ...... (USATHAMA 1990) ...... 1-1 Appendix K Common plant and wildlife species at YPG ...... K-1 Appendix L Photographs of unexploded ordnance at JPG ...... L-1 Appendix M Comments and responses on the Draft Environmental Impact Statement for closure of Jefferson Proving Ground, Indiana and realignment to Yuma Proving Ground, Arizona ...... M-l

Appendices A through K do not appear in this Final EIS; they are available for review in the Draft EIS. .

vi LIST OF TABLES

S1 Summary of new construction required for proposed action . . . . . S-3 s-2 Summary of potential impacts at the jefferson Proving Grounds . . S-5

s3 Summary of potential impacts at the Yuma Proving Grounds . . . . s-7

54 Compliance with environmental statutes (ongoing) ...... s - IO

2.2-1 Jefferson Proving Ground migration of workforce position authorizations ...... 2-8

1.3.1-1 General soil characteristics of JPG ...... 3 - 10

J.3.1-2 Summary of significant groundwater analytical results at the Gate 19 Landfill and Solvent Disposal Area of Bldg. 279 ...... 3- 15

J.3.1-3 Common wildlife species and associated habitat types in Jefferson Proving Ground ...... 3 - 2(1

J.3.1-4 Threatened, Endangered and Sensitive Wildlife known to exist or occur in the immediate vicinity of the JPG property ...... 3 - 25

1.3.1-5 Historical (1980) use of insecticides and herbicides at jPG , ...... 3 - 30

J.3.3- 1 Summary of rounds fired at JPG over a 2-year period ...... 3 - 39

J.3.3-2 Summary of Indiana Air National Guard aircraft operationsat JPG ...... 3 - 39

J.3.4-1 Selected socioeconomic information for the JPG region ...... 3 - 54 J.3.4-2 Existingland use-JPG ...... 3 - 55

J.3.4-3 County Land uses in the JPG vicinity ...... , . . . . . , . . . 3 - 59

Y.3.1-1 Estimated properties and features of soils ...... 3 - 84

Y.3.1-2 Sensitive plant species that occur or potentially occur on YPG . . . . 3 - Oh Y .3.1-3 Sensitive wildlife species occurring or potentially occumngonYPG ...... 3 - ‘)ti -

vii LIST OF TABLES (concluded)

Y.3.1-4 Sensitive wildlife species in the vicinity of YPG ...... 3 - 101)

Y.3.2-1 Air quality data from the Yuma Air Monitoring Station for 1982 through 1989 ...... 3 - 1117

Y.3.2-2 Estimated emissions from major activities at YPG ...... 3 - IO')

Y.3.4-1 Reservation land within YPG ...... 3- 125

Y.3.4-2 Landuse ...... 3 - I20

Y.3.4-3 Total full-time and part-time employment ...... 3 - 171

Y.3.4-4 Summary of characteristics of school districts potentially affected by proposed alignment ...... 3 - 133

Y.3.4-5 Private schools and universities where YPG dependents attend ... 3- 134

Y.3.4-6 Medical facilities at Yuma, Arizona ...... 3 - 135

Y.3.4-7 Water supply at WG - 1985 ...... 3 - 144

Y.3.4-8 Summary of existing hazardoudtoxic waste generated at the YFC 3 - 14X

Y.4.4-1 Summary of economic impacts at YPG realignment associated with JF'G closure ...... 4 - 34

Y.4.4-2 Estimated annual economic benefits at YPG during the implementation of the realignment activities ...... 4 - 35

viii LIST OF FIGURES . 2.1-1 Regional setting map of the JPG ...... 2-0

2.1-2 Yuma Proving Ground and vicinity ...... 2-4

2.1-3 Geographic regions within Yuma Proving Ground ...... 2-5

2.4-1 Facilities for proposed action. YPG (IDA 1990) ...... 2-20

2.4-2 Facility layout for proposed action. YPG ...... 2-21

2.4-3 Additional airspace for proposed action. YE ...... 2.20

2.4-4 Facilities for alternative configuration in East Arm. YPG ...... 2.24

J.3.1-1 Glacial land features of Indiana ...... 3-0

1.3.1-2 Stream corridors within the JPG ...... 3-4

1.3.1-3 Bedrock geology of the JPG ...... 3.6

J.3.1-4 Major subsurface geology structures of Indiana ...... 3-7

13.1-5 Soil associations of the JPC ...... 3.11

J.3.1-6 Groundwater quality monitoring wells at Gate 19 Landfill and Bldg . 279 .solvent disposal area ...... 3-14

J.3.1-7 Controlled natural resource areas of the JPG(July 1989) 3 .21 1.3.1-8 Location of herpetological stations and unique and rare natural areas of the JPG ...... 3.23

J.3.3-1 Mission related noise contours generated for the JPG ...... 3~40

1.3.4-1 Historic cultural resources identified within the JPG ...... 3.43 J.3.4-2 Map of historic and/or modem ground disturbance that might limit the archeological resources based on the JPC ...... 3.49

ix LIST OF FIGURES (concluded)

1.3.4-3 Community land use within the JPG ...... 3-51

1.3.4-4 Existing land use within the JPG ...... 3.56

1.3.4-5 Existing land use within the JPG ...... 3.57

1.3.4-6 Regional transportation map ...... 3~ (SI

1.3.4-7 Location of Solid Waste Management Units and other areas requiring environmental evaluation ...... 371

1.3.4-8 Approximate location of impact fields at JPG ...... 3.74

Y.3.1-1 Major topographic features. WG ...... 3.80

Y .3.1.2 Generalized distribution of surficial material. YPG ..... 3. XI

Y .3.1.3 General soil associations. YI’G ...... 3.X6

Y.3.1-4 Arizona Game and Fish Department watering sites on YPG ...... 3. xu

Y .3.1.5 Distribution of plant associations, West Arm of YPG ...... 3. ‘XI

Y.3.1-6 Distribution of plant associations, East Arm of YPG ...... 3.01

Y.3.4-1 ZonesofYPG ...... 3 . 12.1

Y.3.4-2 Generalized land ownership, YPG ...... 3- 123

Y.3.4-3 Existing restricted airspace, YPG ...... 3 . 128

Y.3.4-4 Contaminated areas on YPC ...... 3 .137

Y.3.4-5 Regional transportation system, YPG ...... 3 .139

Y.3.4-6 Landfill and sewage locations, YPG ...... 3- 142

X LIST OF ACRONYMS AND ABBREVIATIONS

AADT Annual Average Daily Traffic AAV: Annual Average ADNL A-weighted day-night level AIRFA: American lndian Religious Freedom Act AIRS Aerometric Information Retrieval System AMC: US. Army Materiel Command APS: Arizona Public Service AQCR: Air Quality Control Region AREE Areas Requiring Environmental Evaluation Be: Beryllium BLM: Bureau of Land Management BOQ: Bachelor Officer Quarters BRACO Base Realignment and Closure Office BTU: British Thermal Units CAA: Clean Air Act CDM: Camp Dresser & McKee, Inc. CDNL C-weighted day-night level CEQ: Council on Environmental Quality CERCLA: Comprehensive Environmental Response, Compensation & Liability Act CERL Construction Engineering Research Laboratory CFR: Code of Federal Regulations cfs: Cubic feet per second CO. Carbon monoxide CWA: Clean Water Act DA: Department of the Army DARSE: Department of the Army Relocation Services for Employees dB: decibels; dBC, C scale; dBA, A scale Dcs: Defense Communications Systems DEE. Draft Environmental Impact Statement DEH. Directorate of Engineering & Housing DERA: Defense Environmental Restoration Account DERP: Defense Environmental Restoration Program DLES: Directorate of Law Enforcement &I Security DNT. Dinitrotoluene DOD. Department of Defense DOT Department of Transportation DU Depleted Uranium DZ: Dropzones

xi LIST OF ACRONYMS AND ABBREVIATIONS (continued)

EDR Electrodialysis Reversal EIFS: Economic Impact Forecasting System EIS Environmental Impact Statement EMT Emergency Medical Technician EO: Executive Order EZ Extraction Zones FAA. Federal Aviation Administration FEMA: Federal Emergency Management Agency FHWA Federal Highway Administration FIFRA: Federal Insecticide, Fungicide and Rodenticide Act FMV: Fair Market Value FWPCA: Federal Water Pollution Control Act Fy: Fiscal Year gpd: Gallons Per Day gpm: Gallons per minute HAP Homeowners Assistance Program HE: High Explosive HMX: 1,3,5,7-tetranitro-l,3,5,7-tetraazacyclooctane HSC: Health Services Command ICM: Improved Conventional Munitions ICUZ Installation Compatible Use Zone IDNR: Indiana Department of Natural Resources IDOT Indiana Department of Transportation IDEM: Indiana Department of Environmental Management IN-ANG: Indiana Air National Guard IRP: Installation Restoration Program 1%: Interstate Commerce IWR: Institute for Water Resources JPG: US. Army Jefferson Proving Ground KFR: Kofa Firing Range kg: kilogram kv: Kilovolts 1: liter L Lacustrine Ldn: day/night noise level LAAF Laguna Army Airfield Ibs: Pounds LF: Linear Feet

Xii LIST OF ACRONYMS AND ABBREVIATIONS (continued) m: meter MEA: Michael Brandman Associates MCA: Military Construction, Army MCAS: Marine Corps Air Station mcg: microgram MCL Maximum Contaminant Level MCLG: Maximum Contaminant Level Goal MEDDAC: Medical Department Activity mg: miligram MIDCOR: Madison Industrial Development Corporation MOA: Memorandum of Agreement NCO Noncommissioned Officer NOE: nap-of-the-earth NEPA: National Environmental Policy Act NHPA: National Historic Preservation Act NO: Nitrogen oxide N02: Nitrogen dioxide NOX, Oxides of nitrogen NOI: Notice of Intent NPDES National Pollutant Discharge Elimination System NRC Nuclear Regulatory Commission NRHP: National Register of Historic Places NWI: National Wetland Inventory OB/OD Open Burning/Open Detonation OCE: Office of Chief of Engineers OCR Oil Circuit Redosure OEA. Office of Economic Adjustment OHNO Occupational Health Nursing Office OMA Operation, and Maintenance, Army ORV: Off Road Vehicle 03 Ozone PA: Preliminary Assessment PAT Product Assurance Testing PCB: Polychlorinated Biphenals PEM: Palustrine emergent PEP Propellants, Explosives, and Pyrotechnics PFO: Palustrine forested PJ5: Position Location System PMl0: Particulate matter, 10 microns or less POL Petroleum, oils and lubricants

xiii LIST 0 P mONYMS AND ABBRBVIA TIONS (continued)

PPM: Parts per million PPT: Parts per trillion PSI: Public Service lndiana PSS: Palustrine scrubshrub PUB: Palustrine unconsolidated bottom PVC: Polyvinyl chloride R: Riverine RCRA: Resource Conservation and Recovery Act RDX: Hexahydro-l~,5-trinitro-l~~triszine RI/FS: Remedial Investigation/Feasibility Study ROD Record of Decision RTV: Rational Threshold Value SARA: Superfund Amendments and Reauthorization Act SCS SOU Conservation Service SHPO. State Historic Preservation Office SO2: Sulfur dioxlde SOP: Standard Operating Procedures SI? State Implimentatton Plan SSI: Screening Slte Inspection SWMU Solid Waste Management Unlb TAV: Twinagent Vehicle TCDD Tetrochloro-dibevzo-p-dioxin TCE: Trichloroethylene TDS Total Dissolved Solids TECOM: US. Amy Testing and Evaluation Command TGR Takeoff Ground Run TMDE: Test, Measurement and Diegnwtk Equipment TNT: Trinitrotoluene TSCA: Toxic Substances Control Act TSP: Total Swpended Particulater TSS: Total Suspended Solids USACE US. Army Corps of Engineers USAEHA US.Army Environmental Hygiene Agency USAF US. Air Force USATHAMA: US. Army Toxic and Hazardous Materials Agency USC: United States Code USD.4: U.S. Department of Agriculture USEPA US.Environmental Protection Agency USFWS: US. Fish and Wildlife Service UXS: US. Geologic Survey

xiv CHAPTER 1 - PURPOSE OF AND NEED FOR THE ACTION

1.0 INTRODUCTION

This document focuses upon the environmental and socioeconomic impacts associatrd with thc implementation of planned base closure and realignment activities within the US. Army. Specifically, the proposed action concerns the discontinuation of the mission, Ihc witldr.iwal from and the closure of U.S. Army Jefferson Proving Ground QPG) near Madison, Indiana and thc realignment of the US. Army Munitions Production Acceptance Test Mission aciministtwxi by the U.S. Army Test and Evaluation Command (TECOM) to US. Arniy Yuma Proving Ground (YIC), Arizona.

1.1 PURPOSE AND NEED FOR THE ACTION

On May 3, 1988, the US. Secretary of Defense formed the Commission on Base Realignmrnt and Closure (The Commission) in accordance with the provisions of the Federal Advisory Conimittcv Act, as amended (5 U.S.C. App. I). The Commission was established to determine thr best process and criteria for the realignment and closure of military installations and to identify which bases should be realigned or closed.

The Defense Authorization Amendments and Base Closure and Realignment Act (P.I.. 100-526) (The Act) was passed by Congress and subsequently signed into law on October 24, 1988. The legislation was an endorsement of the Secretary‘s approach of identifying installations considered to be obsolete, unnecessary, underutilized, or no longer serving essential missions. As such, The Act is a basic agreement between the legislative and executive branches, stating that improvements in the military basing structure could be a means of realizing long-term defense budget savings while not impairing the ability of the various branches of the military to cany out their respective missions.

The primary criterion used by the Commission for identifying candidate bases was the military value of the installation. However, cost savings and the current and projected plnns and requirements for each military service were also considered. The commission focused its revirw on military properties and their uses; not military units or organizational/administrative issucs.

On December 29, 1988, the Commission recommended the realignment and/or closure of 145 military installations. 01his number, 86 are to be closed, five are to be closed in part, and 54 will experience a change (either an increase or decrease) as units and activities are relocated. On Janrinry 8, 1989, the Secretary of Defense approved these recommendations and announctul 111,it thc Department of Defense would implement them. Implementation must be initiated by St~ptcn~bc~r30. 1991, and must be completed no later than September 30, 1995.

The overall base closure program is based on the principle that the national dcfensc c.in btr improved, its costs reduced, and its various missions be made more effwtive through ,I morc efficient structuring of US. military bases. Within this overall principle, the Commission recommended relocating and realigning the mission of product assurance testing citrwntly undertaken at JPG to YE. The Commission's recommendation was bas4 on the necd to incriwv the utilization of Department of Defense (DOD) military facilities and rcduce overiill installaiion operating costs.

JPC and YPG are managed and operated by the U. S. Army under the US. Army 'l'rsl and Evaluation Command (TECOM). TECOM is a Major Subordinate Command of the U.S. Army Materiel Command (AMC). The Current mission of TECOM is to ensure that US. Army matrriel meets required technical performance and safety standards. TECOM currently opvratrs fivc installations and five field operating activities throughout the continental United States, Alaska, and Panama.

The closure of JPG and the realignment action of the JPG mission to YM; will have thv effiri of reducing the number of TECOM-operated installations from five to four. Once thtx action is implemented, TECOM will continue to operate and manage four installations within the Unitcd States: Combat Systems Testing Activity at Aberdeen Proving Ground Installation Support Aclivit) and Headquarters TECOM, Aberdeen Proving Ground, Maryland; Dugway Proving Ground, Utah; White Sands MWie Range, New Mexico; and Yuma Proving Ground, Arizona. At YPC, TECOM will continue to manage and operate the current US. Army armament and munitions testing mission along with the Production Munitions Acceptance Test Mission realigned from JPC as part of the overall base closure and realignment program.

1.2 REGULATORY AUTHORITY

The Act requires that the Department of the Army consider the environmental consequenccs of the proposed closure and realignment actions of military installations selected by the Commission. The environmental impacts must be described relative to the provisions of the National Environmental Policy Act (NEPA) of 1969 (42 U.S.C. 4321 et. seq.), as implcmented by the President's Council on Environmental Quality (CEQ) (40 CFR Parts 1500-1508). In addition, Army Regulation (AR) 200-2 (32 CFR Part 651) provides the policies and procedures followed by ihr Army for implementing NEPA and CEQ regulations.

1-2 The following records, documents, and processes are required as part of the environnirnlal determination on a review process by AR 200-2

1. Notice of Intent (NO]). An NO1 is a public notice prepared by the Army stating thal ,in Environmental Impact Statement (EE) will be prepared and considered. The NO1 to prvpnrr an EIS for this proposed action was published in the Federal Register on May 8, 1989 (IWl~rto Section 5.1).

2. Scoping. Scoping is an early and open process for identifying cnvironnwntal isstws of thr proposed action. The process requires appropriate agency and public participation lollowing the NOI. Scoping specific to this proposed action was conducted in the Jl’G, Indinn~,iriv on June 8, 1989 and in the Yuma, Arizona area on June 26, 198Y. (Refer to Scrlions 5 I I .ii,d 5.1.2, respectively).

3. Environmental ImDact Statement @IS). In this case, an ElS is a detailed written statcsment prepared by the Army and required by NEPA to asses the significant environmental affects of the proposed action of implementing military base closures and realignments selcctcd by the Commission. The EIS provides a basis for informed decision making and allows al:rncy and public review and comment.

The EIS is prepared in a Draft stage and Final stage. This document is considered to be the Final EIS (FEE).The Army has completed the required agency coordination and public prticipition procedures in accordance with CEQ and Army environmental impact regulations as they pertain to NEPA. Comments have been integrated into the text of the FEE as required. Individual comments, responses and associated correspondence are provided in Appendix M.

4. Record of Decision (RODL The ROD becomes part of the environmental documentation as the final decision on the proposed action, as determined by the Army. The ROD

(1) States the decision; (2) Identifies considered alternatives, specifying the alternative considered to be environmentally preferable; (3) Discusses essential Army decision making factors; (4) States how such facton entered into the final decision; (5) States to what extent practicable means to avoid or minimize harm to the environment have been adopted, and if not, why they were not; and (6) Summarizes a monitoring and enforcement program for adopted mitigating iiwasiiri*s.

1-3 CHAPTER 2 - ALTERNATIVES CONSIDERED

2.0 INTRODUCTION

The Act states specifically that the actions of the Commission were exempted from the provisions of NEPA regarding the decision-making process for recommending bases to be closcd or realigned. However, environmental impact analyses concerning the implementation of the Commission's recommendations are still required under the provisions of NEPA, consistent with 'The Act. [luring the process of analyzing the impacts of implementation, the authorizing legislation states that thr Secretary of Defense shall not have to consider 1) the need for closing or realigning a military installation which has been selected for closure or realignment by the Commission; 2) the ned for transferring various missions, functions, and operations to another military installation which has been selected as a receiving installation; or 3) the need for studying alternative military installations to those selected.

The alternatives considered in this document are limited to the No Action Alternative, the Proposed Action and the implementation of the realignment to YPG. As stated above, environmental analyses undertaken within this document are specific to the implementation of the Commission's recommendations of transferring the current mission at JF'G to YPG and the process of closing JPG.

As a result of the exemptions from NEPA provisions described above, no alternatives to the installation selected for realignment by the Commission (i.e. YPG) are considered in this document. At YF'G, the analysis primarily focuses on alternative sites on the installation associated with the proposed construction of the required facilities to support the realigned US. Army Production Ammunition Acceptance Testing Mission. At JPG, the analysis focuses on mission phase-out and withdrawal, property reuse process and potential and possible property commitment to caretaker status. Hazardous waste contamination would be addressed under the U.S. Army's Installation Restoration Program (IRP).

2.1 NO ACI'ION ALTERNATIVE

In accordance with CEQ regulations for implementing the provisions of NEPA (40 CFR Parts 1500- 1508 an evaluation of the No Action Alternative has been included in this document. The No Action Alternative has been established as a benchmark against which the proposed action of realignment and closure may be compared and evaluated from a point-of-reference of current-level baseline

2- 1 conditions. (Refer to Chapter 3, Affected Environment, Section J to further review JPG bawlinr environmental conditions, and Section Y, YPC baseline conditions).

JPG is located in southeastern Indiana approximately seven miles from the Indiana-Kentucky border within Jefferson, Ripley and Jennings Counties (Figure 2.1-1). JXcontains 55,264 acres of land within a completely fenced perimeter. The installation is approximately 18 miles long in a north-south direction and varies east-west from three to six miles in width.

JPG is a designated Class I1 Munitions Test Center of the U.S.Amy. The primary mission of JI'C is to perform production and post-production tests of ammunition components and end items as wdl iis to conduct propellant assessment, master calibration, and evaluations of ammunition/weapons systems and components for the U.S. Amy. As the principal test and evaluation facility of conventional production munitions for the U.S. Amy, JPG currently performs approximately 85 percent of the Army's Production Ammunition Acceptance Testing. Also, the Indiana Air National Guard makes use of some 1,033 acres of the installation as an air-to-ground impact area for operational training requirements. JIC currently employs a total of 421 persons. Of the overall total, 407 are civilians and 14 are active duty military.

YPC is located in the southwestern comer of Arizona within Yuma and La Paz Counties (I"g41 ure 2.1-2). The City of Yuma (population of approximately 50,OOO) is located approximately 30 miles southwest of YPG.

YPG contains approximately 1,310 square miles (838,174 acres) and is fashioned in a "U shape with the Kofa National Wildlife Refuge in the middle of the "U" (Figure 2.1-3). The site is bordered by the Imperial National Wildlife Refuge on the west, and by primarily Bureau of Land Management and some privately owned lands on its other borders.

YPG is a designated Class I Munitions Test Center of the US. Army. The principal mission of YPG is to plan, conduct, analyze, and report the results of development tests and other tests; review plans for and monitor the conduct of development testing planned or conducted by proponent materiel developers, producers, and contractors in accordance with integrated testing cycle policies for tube artillery systems, aircraft armament systems, air delivery systems and air movable equipment, mobility equipment and other materiel. Also, the mission is to plan, conduct, analyze and report the results of desert environmental tests on all classes of materiel; provide technical support to other Federal government agencies; provide, coordinate, and control assigned air and land space for TXN) agencies requiring these assets in the accomplishment of their missions; provide advice and l:uidiinrc- on test matters to materiel developers, materiel producers, other services, and private industry. .

2- 2 KEY MAP

SCALE IN MILES 0- 5 10

Figure 2.1-1. Regional setting map of the JPG.

2-3 I i I NEVADA \. I UTAH J' COLORADO \, : I

PACIFIC OCEAN

Not to Scale

Figure 2.1-2. Yuma Proving Ground and vicinity.

2-4 ,------I-, I I I I i---- I i NORTH I i CIBOLARANGE + I I 1 r-- I I I I I I i SOUTH I ' CIBOLARANGE I i i EAST i ARM I I I I

0 IO I I i (USACE - MBA) 1907 Source: LA and miles

Figure 2.1-3. Geographic regions within Yuma Proving Ground

2-5 Figure 2.1-3 delineates the various ranges and geographical regions on YPC. The North and Soutf Cibola Ranges are located within the Western Arm of YPC. These ranges are primarily used for testing of aircraft armament systems and air delivery systems (material and personnel drops). The Main Administrative area is located south of the Cibola Ranges and contains the various buildings associated with administration and operation of the facility. The Mobility Test area is located in the southwestern portion of YPG and contains facilities for testing and evaluation of wheeled and tmckd vehicles. The Kofa Firing Range occupies the central portion of YPC and is used primarily for test firing of 20mm to 16 inch artillery and mortar rounds. Limited military activity (Le., air 10 ground firing, bivouac/support) occurs on the East Arm of the facility.

2.2 THE PROPOSED ACTION

The proposed action concerns the U.S. Army JPC and YPC installations relative to Public Law 100- 526. Specifically, this action includes:

The realignment of the JPC Munitions Production Acceptance Testing Mission to YPG. Mission realignment involves the development of required operational and support facilities at a designated site on the YPG installation as well as the transfer of designated positions.

The closure of JPC

The guidance and description of the closure and realignment of mission and associated workforce and other mission support requirements are contained in the Base Realignment and Closure Execution Plan (The Plan). The Plan was prepared by the Headquarters, Department of the Army (DA), Base Realignment and Closure Office (BRACO), March, 1990. A time-phased workload transfer schedule by component activity and major support areas has been developed to facilitate the transition from JI’G to YPG. This phased execution has been developed to ensure that resources are in place to continue testing while minimizing the impact on customers who must continue to manufacture conventional ammunition during the realignment phase. The following milestones have been determined to accomplish realignment to WC:

Initiation Date: FY91

Construction Start Date: FY93

Move Completion Date: FY95

2-6 The realignment portion of the proposed action involves two principal components: 1) workforce position determinations; and 2) the construction of new facilities at WC to support realignment needs.

2.2.1 Workforce Position Determinations

This section pertains to the transfer of workforce positions required to execute the realigned Production Ammunition Acceptance Testing Mission at YM;. Table 2.2-1 provides a summary of the workforce position determinations as currently authorized at JFC and includes the migration ol workforce positions authorized for transfer to YPG and other installations as well as those positions to be eliminated. The numbers used reflect information available as of March, 1990 in the DA lixc.ciition Plan. As such, the potential exists that the migration plan may be further revised to meet lhr Army's changing needs and circumstances. Further, the numbers in Table 2.2-1 relate to workforce positions and not actual staffing requirements. At this time it is not known how many current JPG civilian employees will accept positions in the newly realigned mission at YPC. A total of 271 civilian workforce positions will be available at YPG.

The proposed relocation of personnel to Fort Shafter or a proposed U.S. Air Force installation are not expected to produce significant impacts. This conclusion is based on the small numbers of personnel involved (Table 2.2-1) and the fact that no new construction or significant resources will be required to support these realignment actions. The consideration of personnel relocation to Ft. Shafter or US. Air Force personnel attached to the Indiana Air National Guard is excluded under NEPA. Therefore, these actions will not be further addressed.

2.2.2 The Closure of JPG

In the specific case of JPG, closure is defined as the discontinuation of operations in prcparation for the timephased realignment of the Production Ammunition Acceptance Test Mission to another sitr. According to The Plan for realignment to YPG and the closure of JPG, major unit movements will depart JPC beginning in FY93. As the workload departs JPG, the installation will begin to close. Un- needed equipment and instrumentation will be disposed of and facilities and other physical plants will be closed and secured. The milestone for the move completion date to YPG is by M95. Public Law 100-526 mandates that all realignment and closure actions must be completed no later than September 30,1995. TpG's accountability and overall maintenance will continue to be assumed by the Army during the transition period of workload transfer, official closure, and possible commitment to caretaker status.

2-7 Table 2.2-1. JeffersonProving Ground migration of workforce position authorizations.' MILITARY CIVILIAN TOTAI.

JPG Workforce Posltlon Migration Paths: To: Yuma Proving Ground TECOM 0 265 265 TMDE 0 5 5 HSC -0 -1 -1 WPG Subtotal) 0 27 1 27 1

To: Fort ShaTter. Hawall [HSC) 0 1 I To: US. Alr Force Installallon -11 0 -I1 1INANG)" Poddon Migration Subtotal 11 272 283

Po8ltlo1~~To Be Eliminated

From: AMC (Currentlyat JPG) 3 116 119 From: ISC [Currently at JPG) -0 -19 -19 EUminated Subtotal 3 136 138

JPG BASELINE TOTAL CURRENT PERSONNEL AUTHORIZATIONS (EqdTotal of Items 1-2) -14 401 -421 Abbrrrlatlonr:

AMC = US Army Materiel Command TECOM = US Army Test and Evaluation Command TMDE = US Army Test. Measurement. and DLagnosUc Equlpment HSC = US Army Health Systems Command ISC = US Army Information Systuns Command INANG = lndlana Atr National Guard

Noter: Flgures are as of March. 1990 and may change as the DOD continues to reallgn and reduce the budget.

** The INANC contingent of active duty rc8e~vesat JFG wlll be lransfemd to an as yet undeslgnated USAF Installation.

Source: Base Reallmment and Closure Execution Plan for P.L. 100-526. 102 Stat. 2623,11988). Defense Authorlzatlon Amendments and Base Closure and Reallgnment Act. HQ. Uept of the Army. BRACO. March 1990.

2-8 2.2.3 JPGCaretaker Status

Due to long term hazardous waste contamination problems and the potential that unexplodtd ordnance could be found virtually anywhere on the installation, it will not be possible to immediately dispose of all the property. As such, it may become necessary for the Army to establish a property caretaker status program once JPG is officially closed in FY95. All or part of the JKpirccl may bc committed to a caretaker status and administered by the Army. A definite time period of carctnkrr status has not yet been determined.

Caretaker status will consist of the following general functions as determined by an analysis conducted by JPG:

Protect the public through the maintenance of the security fence and the required public safety service areas of security and tire protection.

Provide low-level maintenance functions to prevent the deterioration of the existing JPC physical plant. Personnel requirements would include those required to maintain utilities, road/grounds/buildings, vehicle maintenance, supply and transportation, telephone and provide general maintenance. Also, personnel trained in the demolition of high explosives would be required to provide additional on-post safety during the caretaker period should the need arise.

Provide personnel to camy out the low-level administrative functions.

Continue to allow controlled deer hunts for natural resource management.

Maintain historical and archeological resources.

At this time, specific personnel requirements for the provision of a caretaker period are unavailable. Caretaker staffing levels will be determined during closure as specific needs are identified. Although all previous mission operations and programs would no longer be undertaken at JPG, some programs in the areas of natural resource management would still be required. The Army will prepare a Natural Resources Management Plan that will address resource concerns at JK. Timber management will be addressed in this Natural Resources Plan.

The timber harvest program would continue and probably expand. The program is carried out through a competitive biding basis. The current timber harvest program a1 JI’G produces approximately w),OOO-300,OOO board feet of lumber annually which produces approxininkcly. $80,000-

2-9 $1OO,ooO of local revenue. currently manages approximately 15,000 acres as part of the timber harvest program. During thecaretaker period, the annual timber harvest program could be expected to triple in terms of acres that could be effectively managed and board feet of lumber produced.

The other program regarding natural resourre management that is expected to continue is the annual deer harvesting program. The current deer population on the installation is estimated at between 3,5004,500, which is considered by JPG Natural Resource Management personnel to bc at a level nearly three times higher than normal off-post levels. As such, a primary reason for continuing the harvest program will be to prevent continued overpopulation in the area and related impacts such as herd starvation, disease and highway safety.

In tern of facilities at JPG, it is expected that the Old Timbers Lodge will continue to be used as the on-post headquarters for carrying out the deer harvest program in the former test range area of JPC. Other facilities would be used by caretaker personnel on an as-needed basis.

2.2.4 Other Considerations of the Proposed Action

A Programmatic Agreement was executed on February 5, 1990 between the Department of the Army, the Advisory Council on Historic Preservation, and the National Conference of State Historic Preservation Officers (Appendix B). The Programmatic Agreement stipulates that Section I10 and Section 106 responsibilitiesunder the National Historic Reservation Act (NHPA) will be completed by the.Army prior to initiation of construction activities or disposal of lands. In instances where the Army NHPA responsibilities have not been fully implemented, the Army will stipulate in the ROD that the NHPA has not yet been complied with, and that no action will be taken which would foreclose completion of the Army's responsibilitiesunder the NHPA.

Consultation is underway between the Department of the Amy, the Advisory Council on Historic Preservation, and the Indiana and Arizona State Historic Preservation Officers concerning closure of the JPG and realignment to YPG. The cooperating agencies are developing procedures for the identification, evaluation, treatment and management of historic properties at the installation prior to closure of JPC. The procedures proposed include the provision for the security, stabilization, protection and maintenance of structures listed or determined eligible for inclusion in the National Register (in accordance with Army Technical Manual 5-801-2).

2- 10 Base Realignment and Closure Environmental Reetoration

This EIS addresses closure of JPG and the realignment of the mission to YPG. The document does not address impacts associated with potential remediation activities at JPC. Hazardous materials-are discussed to the extent that they affect or are affected by closure or realignment. An overview of the environmental restoration strategy is provided below.

Jefferson Proving Ground is responsible for insuring that its operations are in compliance with hazardous/toxic materials regulations such as the RCR4, the Toxic Substance and Control Act (TSCA), and the Clean Air Act. The U.S. Army Toxic and Hazardous Materials Agency (USATHAMA) will undertake the identification and remediation of Contamination rcsulting from installation activities.

The Installation Restoration Program (IRP) process, under which the base closure environmental restoration activities will take place, was developed by the US. Army to identify and remediate environmental contamination resulting from past and present operations that could pose environmental health risks. The initial stage of the JPG IRP consisted of an Initial Installation Assessment (records search), which was conducted in March 1980 (USATHAMA 1980). Due to changes in environmental laws, the advent of environmental problems discovered subsequent to the original onsite visit, and changes in the mission at JPG, a reevaluation of the installation was conducted in 1988. Based on the information gathered during the reevaluation, the initiation of the next phase of the EW, a remedial investigation, was begun. The remedial investigation focused on groundwater contamination by volatile organic compounds (VOCs) detected in monitor wells around the Gate 19 Landfill and suspected in the vicinities of Buildings 279, 602, and 617. This study was designed to identify the sources and quantify the concentration of any potential contamination of concern.

Due to base closure, the scope of the IRF' was expanded and an Enhanced Preliminary Assessment (USATHAMA 1990) was prepared to include unexploded ordnance, asbestos, polychlorinated biphenyls (PCBs), depleted uranium, underground storage tanks, and other forms of contamination not normally investigated as part of the I". The objective of the enhanced preliminary assessment was to examine site activities, determine the quantity of selected hazardous substances present, and evaluate the potential pathways for contamination migration which would affect public health and the environment. The results of the JPG Enhanced Preliminary Assessment are summarized in Section J.3.4.6.

The next phase of the environmental restoration process prior to the release of the property is a Remedial Investigation/Feasibility Study. The Army is planning to conduct an RI/FS for the

2-11 cantonment area south of the main firing line. This is scheduled for completion by P’Y93. Ucvausp an RI/FS of UXO contaminated areas includes the cleanup itself, the Army is holding the initiatid of an RI/FS in the impact area pending more definitive reuse planning. A sampling program or selected sites and all streams also will be undertaken to determine if contamination is prwcnt in concentrations that would be hazardous to the public or the environment. Cmundwatcr samples also will be collected from monitoring wells located at an impact field (interior JEsNorth areif). These samples will be analyzed for UXO chemical constituents (including heavy metals), pesticides and uranium isotopes. Finally, the Army will continue to fulfill its regulatory obligations afkr JrC is closed. Those obligations include:

The closure of the RCRA regulated open buming and open detonation (OB/OD) units; The closure of the underground storage tanks; The submission of a decommissioning plan to the Nuclear Regulatory Commission (NIW for the depleted uranium (DU)area.

A RI/FS will be preformed on any other area prior to releasing that property from DOD controt

General ProDertv Disposition Process

Pursuant to The Act, the closure and realignment must be initiated no later than September 30, 1991, and completed no later than September 30. 1995. The disposal of property cannot begin unt;‘ an environmental evaluation and any required restoration of the property is completid.

2.3 REUSE POTENTIAL OF JEFFERSON PROVING GROUND

This section discusses the local JPG community reuse planning process and reuse potential of the surplus US. Army property once closure and clean-up take place. Reuse planning at JPC is considered a long-term process. The future reuse and associated impacts will be addressed in future NEPA analysis and documentation.

2.3.1 JPG Reuse Planning

The Base Closure and Realignment Act included provisions for the DOD, Office of Economic Adjjtment (OEA) to assist communities located near a US. military installation scheduled for closure. In the case of JPG, the OEA has helped to form the JPG Regional Development Board (The JPC Board). The JPC Board is comprised of representatives from local municipalities and jurisdictions, interested Federal and State lawmakers and organizations, and interesttd public and private groups. The JPG Board has initiated a reuse planning process for JPC based on an ongoing

2- 12 local analysis of reuse- related information, alternatives, and implementation capabilities. The JPG Board is currently in the process of organizing various advisory panels to aid in the process of JrC reuse planning and plan implementation. The U.S. Amy Corps of Engineers, Louisville District, Real Estate Division is also working in coordination with the JPG Board and OEA efforts.

Reuse planning and remediation are interrelated processes. Current remediation planning includes an RI/FS of the cantonment area and additional monitoring. The Rl/R at JM:will cover the 3,000 acres, south of the firing line The RI/FS will not include the evaluation/cleanup of UXO north of the firing line. The RI/FS is scheduled to start in October 1991 and be completed in September 1993. A function of the RI/FS is to cleanup the area south of the firing line. The cleanup methods to be used will be based upon the environmental hazards identified, the resulting risks, and the effectiveness of cleanup for the desired future use.

2.3.2 IPG Property Reuse Potential Scenarios

Three scenarios have been developed to investigate and analyze the practical reuse potential of the property, given the existing environmental constraints of the JPG property. These are: indefinite standby status, unrestricted use and restricted use.

Indefinite Standbv Status

Setting aside JPG on a standby status would render the installation unavailable for reuse for an indefinite period of time. Infrastructure would be maintained in standby status and the facility could be reactivated should future demand for armament testing exceed active facility capabilities. The property would be retained and site security measures would be maintained by the Army until the facility is reactivated or the property made available for reuse.

This option would require maintenance of a caretaker staff and repair and maintenance of the perimeter security fence as well as other JFG physical plant and utilities. The concept of indefinite standby status assumes the following impacts:

- Long-term maintenance costs to DOD and the fact that the property will remain a long- term government liability.

- Prospect of DOD not being able to realize any economic benefits or revenue from the potential sale of the property.

2- 13 - Future reuse options could not be implemented.

This scenario would be a long-term extension of caretaker status discussed in Scrtion 2.2, The accountability and operation of JPC will be maintained by the U. S. Army while in caretaker status.

Unrestricted Use

The unrestricted use scenario assumes that at some point the entire 55,264 acres could become available for reuse. Unrestricted use is based upon the assumption that complete remediation of all contamination will be accomplished by the Army; as such, the attendant human and environmental risk factors that now preclude the concept of unrestricted use will have been eliminated. JPG can not be rendered risk-free for all forms of unrestrictcd land use activity in the foreseeable future. A risk-free environment may not be a feasible option for various reasons including:

Extensiveness of overall contamination of unexploded ordnance.

Currently unavailable economic remediation technology in regards to unexploded ordnance. There is clearance technology available but it is labor intensive and expensive.

Lack of available funds to pay for extensive cleanup required for unrestricted use.

Extremely long timetable for cleanup expectations,

Therefore, the potential for unrestricted use of JPG is not considered feasible on the basis of existing technology and resource availability at this time.

Restricted Use

The concept of restricted use assumes that specific areas and facilities within the installation would be available for various land reuse activities at some future time. Other areas would continue under Army stewardship and remain fenced off from access or encroachment while, or until, cleanup is accomplished. The concept of restricted use assumes the following:

There are no portions of JPG that may be used or excessed at this time, until further research is undertaken concerning the location and removal of unexplodtd ordnance

2-14 and hazardous wastes. The N/FS of the cantonment area is schedule for completion in 1993.

The Army would still accomplish all required regulatory, technologici~l,and lunding efforts to decontaminate sitespecific areas, such as the cantonment area.

The prioritization of reuse options from which the Army and the community would be able to derive the highest and best use from the property within an efficient time frame.

Given the significant level of environmental contamination at JFG, the restrictcul 11sc concept could provide all interested parties involved in the closure and reuse proccss with this mofit practicable means of accomplishing an effective and realistic reuse planning strategy.

2.3.3 Alternatives Considered Potentially Viable

The alternatives presented herein best suit the concept of restricted use, given the existing information concerning uncertainties posed by the extensiveness of site contamination and cleanup constraints. Each alternative was chosen for further analysis as potentially viable and Icasible based upon the consensus of active reuse participants and the screening criteria. The alternatives under consideration are:

LikeKindUse

General Aviation Facility

Regional (Fivecounty) Landfill

Correctional Facility

Implementation of the Like-Kind Use alternative would probably preclude other concurrent uses on JF'G property. The General Aviation Facility, Regional (Five-County) Landfill and Correctional Facility alternatives could be implemented either individually or in combination. In addition to conforming to most screening criteria requirements, each selected alternative possesses a common thread that sets it apart from the remainder of the alternatives considered. Each option requires some degree of access control, activity regulation, safety measures, and facility isolation. The alternatives analysis is not intended to, and does not, disallow the possibility that other alternatives may ultimately be implemented. It is meant only to develop the general range of potential reuse options for ipc. .

2- 15 Like-Kind Use. This alternative will not involve the continued use of JPG for ammunition acceptance testing. Privatization is an acceptable reuse option provided the existing mission at JPC is not duplicated.

Like-Kind Use offers an optimal reuse potential given the existing conditions at JPC, including the level of contamination. This type of reuse option could preclude the need to cleanup ordnance. Public access would continue to be strictly regulated and controlled, thus protecting the public from the dangers posed by contamination. Like-Kind Use is compatible with existing on-post land use and is compatible with community land use and economic plans and policies. The infrastructure and facilities for ammunition testing are already in place. The potential impacts to natural and cultural resources within the installation would require further investigation.

General Aviation Facilitv. This alternative involves the use of the JPG airfield facility. The Federal Aviation Administration (FAA) is in the process of conducting a Federal Agency screening process to identify potential real properties that could have importance in future FAA programs. The FAA is seeking two facilities to support the Mike Monroney Aeronautical Center in Oklahoma City. JPC is one of 15 potential DOD facilities slated for closure that have been identified by the FAA for airport- related civilian land use. The process is only in the very preliminary stages of review by the FAA at this time. Specifically, the FAA is seeking a 9,600 square foot computer operations center and a storage facility possessing 50,OOO to lO0,OOO square feet.

The on-post JPG air facility consists of a 5,000 foot fixed-wing runway, taxiways, aprons, and a 24,084 square foot hangar and assorted support buildings. The airfield has been abandoned for nearly 20 years and the area is currently used for the storage of testing related excess supplies, armor plates, and miscellaneous items. The site would require a significant amount of analysis to determine capital improvement costs and general economic feasibility. An environmental remedial investigation/feasibility study (RI/FS) is needed to fully determine the amount of environmental contamination. Airport-related civilian land use is comparable with community plans and policies. The site would require necessary access and security provisions along with all required FAA permits and flight allowance certifications, if applicable. Although a general aviation airport reuse alternative has not been explored beyond the FAA preliminary identification stages, it possesses significant merit to warrant further evaluation.

Reeional (Five-County) Landfill. This alternative considers locating a site of significant size with the proper geophysical requirements to serve a s regional, five-county, solid waste landfill. Such n reusealterdive was suggested by the JPC Board in response to recently mandated state solid waste disposal requirements and rapidly diminishing landfill availability in Southeastern Indiana. From information provided by the JPG Board, the landfill would preferably be located in the northwestern

2-16 sector of the installation to take advantage of the remoteness and favorable terrain. No othrr details have been developed for such a proposal.

A regional landfill could provide local communities with an inexpensive waste disposal option and possibly a significant revenue source in the form of employment, tax revenues, user fees and royaltirs from landfill operaton. The proposal would suit existing land use compatibility requirements since portions of the property have served US.Army landfill requirements in other areas of the inslallalion since 1941. The area is remote from urbanized and community residential areas and public iicwss would continue to be adequately controlled. A landfill would also be compatible with comniunity land use plans and policies. The landfill alternative would require investigation and assessment to determine the extent of unexploded ordnance contamination in the northwestern sector. Also, such an initiative could require an investigation and assessment of significant natural and cultural resources which are abundant in this least developed area of the installation. The landfill reuse alternative merits further evaluation.

Correctional Facilitv. This alternative would focus on the location, construction, and operation of a Federal, State or county prison. The Defense Authorization Act of 1989 (P.L. 101-189, Part C, Scc. 2832) requires that installations rendered as excess under the Base Closure Act (P.L.100-526; 102 Sta. 2627) should be seriously considered for use as prisons and drug treatment centers, as appropriate. Such real property is thus given public benefit priority to wage the war on drugs through the provision of adequate penal, correctional, or drug treatment facilities.

The prison would preferably be located in the northeastern portion of the installation to take advantage of the area's remoteness away from local population centers. No other details were available for evaluation.

A prison would aid the local area in it attempt to offset the potential negative economic effects of JPG's dosure. It could provide direct and indirect economic benefits in the form of direct employment and employment in support services such as food service and prison clothing manufacturing. Potential tax revenues could be generated if the facility would be built and operated by a private company. A prison would conform to existing on-post land use since a facility would require similar needs for strict access control, security, and facility isolation. It would seem to initially conform to local community plans and policies since it was suggested by the JPC Board. However, more detailed feasibility and facility analyses will be required to more fully determine general market feasibility. Detailed environmental and RI/FS studies will also be required as old mine fields and impact areas were identified in the northeast sector. The facility would require a cultural and natural rrsoiircr assessment since it would be located in a resource rich area.

2- 17 2.4 WMA PROVING GROUND IMPLEMENTATION ALTERNATIVES

Closure of JPG and the realignment of its munitions testing activities at YPC will require the transfer of personnel positions. A maximum of 271 civilian work force positions would be transferred to WG. These numbers are expected to continue to change slightly as DOD continues to realign and reduce the budget.

The transfer of JFG testing workload to YFG will result in an intensification of activities at YI’G. Currently, YPG has an annual testing load of approximately 1.2 million direct labor hours. Approximately 50 percent of this testing load involved munitions testing. Most of the munitions testing at YPG are associated with research and development (R&D). This involves testing of munitions during the development stages for both military agencies and civilian contractors. The additional work load from JFG involves primarily production acceptance testing (PAT) of munitions. PAT involves the testing of a sample of each lot of munitions produced by military contractors to assure that the munitions meet government standards. It is estimated that from 160,000 to 180,000 direct labor hours of testing would be transferred to YPG (Institute for Defense Analysis [IDA] 1990). Since the R&D testing currently at YPG involves some different operations and techniques than the PAT activities to be transferred to WG, additional facilities would be required to allow both activities to occur without major scheduling delays and impact on both testing missions. Potential implementation alternatives for these facilities are described in the following subsections.

2.4.1 Proposed Action

The Institute for Defense Analysis (1990) was tasked with the assignment to review potential implementation alternatives as to both cost and feasibility. Their recommended action which has become the proposed action involves the intensification of use of the central Kofa Range. Construction of additional facilities and gun emplacements would be required in the area now used for munilions testing activities at the Kofa Range. The following subsections describe the major features of this plan.

2.4.1.1 General Description of Activities

Implementation of the relocation of JXmissions to YPG involves the integration of the JPG munitions test workload into the west end of the Kofa Firing Range. Construction of additional facilities including artillery and mortar firing positions, direct fire range, ammunition storage and handling facilities, utilities, and communication facilities would be required in the areas already supporting the existing operations at the Kofa Range. Figure 2.4-1 generally outlines the configuration of this alternative. The general objective of the proposed action is to utilize existing range facilities to

2-18 the greatest extent possible with construction limited to necessary facilities to support the additional PAT mission of JPC. Support for the additional personnel and logistic requirements will bc accommodated by existing YPG facilities.

Associated with the proposed action is the placing of additional firing in alternative locations. A direct fire range could be placed south of Pole Line Road. This area is within YPC, hut oiitsidc of \hr restricted air space boundary. The restricted air space boundary would requirc expansion ti) accommodate this new range.

In addition to theconstruction of facilities, the IDA plan also calls for establishment of a computer aided scheduling and range command and control system for the Kofa Range and other ammunition test areas. It is expected that this central system will aid in the efficient scheduling of both R&D and PAT functions. The plan also recommends the transfer of workload from JPC to YPG as early as possible during the realignment period.

The estimated cost for facility construction is $82.2 million. One time expenditures non-construction would be $50.0 million which will result in a total realignment cost of $132.2 million (USlIA FY92 Budget Estimate).

2.4.1.2 New Facilities Required

Table SI provides a listing of the proposed new facilities required for the accommodation of the JPG workload to YPG. These facilities are shown in Figure 2.4-2.

Direct Fire Ranee-

Two additional gun positions would be constructed south of Pole Line Road to accommodate direct fire testing. The approximate location of these facilities are shown in Figure 2.42. Each gun position would consist of a two-bay covered firing barricade. Most of these facilities will be placed into existing testing areas. Figure 2.42 illustrates how JPG testing will be incorporated into the YPC firing line.

The Direct Fire Facility will accommodate both DU and non-DU test munitions. An amendment to the NRC license will be required for the DU munitions. Additionally, a DU catchment facility will be emplaced to receive the DU projectiles upon impact. This will maximize the safe recovery of these items and thus minimize environmental impacts associated with release of DU into the environment. Any new waste streams involving hazardous or toxic wastes will also require notilication. to lhc Arizona Department of Environmental Quality.

2- 19 --1 I I I PROPOSED NEW FACILITIES

1. Direct Fve Range 2. Artillery and Morw 3. hument Operations Center 4. %PPort and Maintenance Facilities 5. Ammunition Preparation I 6. Ammunition Handling 7. Ammunition Storage 8. Ubration Test Facility 9. Ammunition Test Facility 10. Utility services I I 11. Communications I

I i

MILES

0 10

Figure 2.4-1. Facilities for proposed action, YPG (IDA 1990)

2 - 20 Artillerv and Mortar Firine Positions

An Artillery and Mortar Firing Position are proposed to be constructed on the south section of Yl'C. Observation and support facilities are in place.

Sp~ortand Maintenance Facilities

As listed in Table SI and depicted in Figure 2.4-2, nine facilities in addition to the Direct Fire 11ange and Artillery/Mortar Firing positions will be required. These facilities are proposed to be placed near existing similar facilities. Included in the facilities are the Armament Operations Center, Support and Maintenance Facility, Ammunition Preparation Facility, Ammunition Storage Facility, Ammunition Handling Facility, Ammunition Test Facility, Vibration Test Facility, Communication facilities and associated utilities.

2.4.1.3 Addition to Restricted Air Space

Currently the Kofa Firing Range is within restricted airspace area R-2307. This designation reslricls aircraft use at all altitudes north of Pole Line Road. Direct fire ranges constructed south of Pole Line Road will require approval from the Federal Aviation Administration (FAA) to establish a controllcd firing area. The Controlled Firing Area necessary for the Direct Fire Range would be from surface to 3,000 feet above ground level. This special useair space has recently been negotiated with the FAA to accommodate this new range. Figure 2.4-3 provides a general delineation of the area required for the additional restricted airspace.

2.4.2 Other Alternatives Considered

2.4.2.1 Realignment of JPGActivities to East Arm

Initially, TECOM proposed the construction of a new firing range on the East Arm of YPC. A full new facility in the southeastern portion of YPG nicknamed "Jeffersonville" would be constructed lo support the new range. Existing state and county roads would primarily be used for access. New road construction would begin from the railroad track at Growler, Arizona, northward to the proposed new cantonment area. Figure 2.4-4 provides a conceptual plan for this alternative.

At an estimated cost of $135.1 million, this alternative was not considered cost effective by the IDA (1990) especially in light of a projected decrease in munitions testing requirements due to relieving of

2 - 22

..~ . , .. . .. - Figure 2.4-3. Additional airspace for proposed action, YPG.

2 - 27 7-1 I-7 I BASE CLOSURE PROJECTS

I 1. Direct Fue Range 2. Artillery and Mortar Range 3. Technical Operations Center (TOC) 4. SUPPW Maintenance Facilities 5. Security and Emergency Secvices Fac. I 6. Ammo Preparation Facilities b.-\7. Ammo Handling Facilities 8. Ammo Storage Facilities 9. Ammo Test Facilities 10. Access Road

I I

2 - 24 tensions in eastern Europe. Additionally, use of the East Arm as a firing range would crratc significant impacts to plant and wildliie resources, and cultural resources. Additionally, thrrc, would be extensive potential ordnance contamination of an area relatively free of contamination. '1'111s I alternative may also impact housing and schools in communities east of Yuma. I 2.4.2.2 Reduced Realignment of JPG Activities to East Arm This alternative would involve the construction of ranges without a new "Jeffersonville" on the Ens1 I Arm of YPG. This alternative was considered infeasible due to the long distance of the rangr froin existing support facilities. Additionally, there would be significant environmental impacts as I described above for the Jeffersonvillealternative. I 2.4.3 Alternatives Considered but Eliminated Several implementation alternatives were considered and eliminated from further consideration due to feasibility, cost, or environmental concerns. These alternatives include the realignment of JIY; I activities to the West Arm (North and South Cibola Range), no new facilities construction and phasing I of the realignment. 2.4.3.1 Full Realignment of JPG Activities to West Arm

I Full realignment of JPG activities to the West Arm would likely require the construction of new facilities similar to "Jeffersonville" proposed for the East Arm in the Cibola Range. This cost would be similar to the JeffersonvilleAlternative and would not be considered cost effective. Additionally, since I the West Arm (North and South Cibola Range) are primarily used for aircraft gunnery use and similar functions, use of this area for artillery testing would result in a substantial conflict in missions at YPC. I There would also be substantial impacts to wildlife resources and to cultural resources. I 2.4.3.2 Partial Realignment of JPG Activities to West Arm This alternative would include the establishment of a new range on the Cibola range of the West I Arm without the construction of a new "Jeffersonville". The alternative is not considered feasible due to the logistical problems associated in using existing support facilities several miles from the range as well as the potential conflicts in sharing the firing range with aircraft munitions testing and related II facilities.

2-25 2.4.3.3 No New Facilities

This alternative would involve the accommodation of the JPG munitions testing workload at YIT: without construction of additional facilities. All testing would be conducted on the Kofa Firing Range. This alternative was not considered feasible and was rejected since lack of additional munitions storage and handling facilities and lack of expanded firing facilities on the Kofa Firing RnnRc would have a high potential to impact YPG's current R&D testing as well as impact PAT activities transkrrcd to YPC.

2.4.3.4 Phasing

This alternative would involve phasing the Mission of JPG into YPG at a slower rate. This alternative was not considered feasible since it would not accomplish the realignment within the mandated time frame. Additionally, impacts would be the same as described for the proposed action although the impact may be stretched out over a longer period of time.

2-26 CHAPTER 3 - AFFECTED ENVIRONMENT

3.0 INTRODUCTION

The purpose of Chapter 3 is to provide information on the existing conditions within JIY; and YIC. The physical environment, habitats and associated wildlife and vegetation, noise, and Iwtnat1 environment are described based on available information. The affected environment at JIY; IS described in Section J and the affected environment at YPG is described in Section Y. Ch.ipti*r 3, therefore, provides a basis for understanding the consequences of closure of JPC and realigtiitiiwt to YPG. Consequences (impacts) of these actions are addressed in Chapter 4.

SECTION 1 - 1EFFERSON PROVING GROUND

J.3.1 NATURAL ENVIRONMENT

J.3.1.1 Climate

The climate at JPG is classified as continental, since the site is little affected by the nearest large bodies of water, Lake Michigan and Lake Erie, each about 250 miles to the north-northwest and northeast, respectively. The reference point for climatic data is the cooperative station at Madison, 8.7 miles to the south of JPC.

Continental climates are characterized by a broad range in temperature averages and extremes between winter and summer. In the JPG area, where the annual average temperature is about S5T, January temperatures average 34OF, with the lowest temperature on record -23°F in 1977. July temperatures average 76%, with the highest temperature on record of 106'F in 1954.

Annual precipitation averages about 43 inches, generally well distributed from month to month but with highest amounts in the spring and lowest in the fall. However, spring and summer droughts for rather prolonged periods are also on record, with adverse effects on crops and the economy. Winter precipitation usually falls as light snow, except when marked winter depressions occasionally pass eastward to the south of Indiana, and heavier snowfalls in individual storms lead to exceedances of the annual normal accumulation of 16 inches.

3-1 J.3.1.2 Topography

JPGis located on the Muscatatuck Regional Slope of the Till Plains Section of the Interior I.owl,inc. Physiographic Province (Figure 1.3.1-1). The Muscatatuck Regional Slope is characterized by till dt*piisits capping a rolling limestone plateau and crossed by deep rocky valleys. The topography of the solrthcrn two-thirds of JPG is flat, while that of the northern third is gently rolling.

Six almost parallel stream conidors flow across the site in a general west-southweslcrly dirivtion, as follows (Figure 1.3.1-2):

Otter Creek, which traverses the extreme northwestern comer of the site, crossing from I

Graham Creek, a fairly substantial waterway south of Otter Creek, flowing also from l

Little Graham Creek, next further south, flowing from Ripley to Jennings County

Big Creek, the largest of the drainages, located south of Little Graham Creek, and lies mostly in Jefferson County.

Middle Fork Creek, the drainage just south of Big Creek, which runs about 1.5 miles north of base headquarters and permanent installations.

Harberts Creek, the southernmost drainage, which runs across the southern tip of JPC, about 2/3 mile south of base headquarters.

Each creek has a welldeveloped drainage net consisting of numerous tributaries. Except for the two southernmost creeks, the drainages have cut into underlying limestone and have formvci slcep banks as much as 75 feet high.

J.3.1.3 Geology and Mineral Reeowes

The Till Plains Section is characterized by young glacial till plains of the Illinoisan glacial pcriod. The section is comprised of silts and clays with minor amounts of gravel and rock fragmenls

3 -.2 Figure J.3.1-1. Glacial land features of Indiana.

3-3 H 0 mi. 1 mi.

LEGEND

Headquartcrs

klHnrbcrts Figure J.3.1-2 Stream corridors within the JPC.

3-4 (USATHAMA 1980). The thickness of the glacial deposits in this region is apprqximately 50 Icc.i (I lill, n.d.). Glacial moraine deposits are absent in the till plain.

The Illinoisan glacial till deposits at JPG are underlain by carbonate units of the from oltfcst lo youngest Ordovician, Silurian and Devonian Periods (Figure J.3.1-3). These units overlie Camhrian clastic and carbonate rocks, which in turn overlie the Precambrian crystalline basement.

Ordovician limestones are exposed in the drainageways of Otter Creek and Graham Creck in tlic northern portion of the Proving Ground. The Black River, Middle Ordovician Limestone is lhc. olcivst unit exposed in the study area. It is fine grained and thickens to the south. The Trcnlon I.inwsloncr overlies the Black River limestone. It is fine to medium-grained, and includes exlcnsivc str;it;i of dolomite and thins to the south. Overlying the Trenton Limestone are interbeddcul slialrs .ind limestones of the Middle to Late Ordovician Maquoketa Group.

Silurian carbonates underlie glacial till deposits throughout most of the JPG (Figure 1.3.1-3). 'I'hc oldest of these, the Brassfield Limestone, is a compact crystalline limestone which lies unconformahly over the Ordovician units. The Salamonie Dolomite is a fine-grained, light gray, porous dolomite and dolomitic limestone overlying the Brassfield Limestone. The Laurel Member of the Salamonie Ddoinite, a hard, light to dark gray limestone with zones of porous brown limestone, is the most widespread unit at JPG. The Louisville Limestone is a light gray to brown, finegrained dolomite or dolomitic limcstone that overlies above the Salamonie Dolomite.

The Devonian Shaly dolomite of the Devonian Muscatatuck Group underlies glacial till in n small area near the southwest boundary of the Proving Ground. These rocks unconformably overlie the Silurian layer (Shaffer 1981). The rocks described above are part of the Cincinnati Arch (Figure J.3.1-4). This structure separates the Illinois Basin to the west and the Michigan Basin to the north.

Mineralization in the carbonate bedrock of JPG includes pyrite and galena in the Trenton Limestone and fluorite and galena in the Muscatatuck Group. Sphalerite is found in most Ordovician, Silurian and Devonian units underlying JPG (Shaffer 1981). The economic potential of the various units is exccllcnt for Trenton Limestone, poor for Maquoketa Group, fair for Salamonie Dolomite, poor for Louisville Limestone, and good for Muscatahrck Group (Shaffer 1981). Silurian and Devonian limestones are quarried in southeastern Indiana for aggregate and high purity chemical-stone products. Ordovician rocks are generally too shaly to be of commercial value (Hill, n.d.).

3-5 C .-m Muscatatuck

S I

......

I I HN

Figure 1.3.1-3. Bedrock geology of the JPC.

3-6 MICIIICAN

Figure 1.3.1-4. Major subsurface geology structures of Indiana

3-7 1.3.1.4 Paleontology

The glacial deposits are essentially free of fossils. Bedrock units of JPG were deposited duriiil; th, Paleozoic Era, when marine invertebrates and marine plants were the dominant life forms. Ordovician rocks of the Black River and Trenton Limestones are rich in skeletal matter of marine inacroinverli,l)ratcs (Laferriere et al. 1986). Silurian and Devonian rocks contain many types of fossil niarinc slit4lfish indicating depositions in shallow, warm seas. The Louisville Limestone includes corals, bmcliiolmds, sponges, crinoids, bryozoans, gastropods, cephalopods and trilobites (Ilexroad et al. 1981). Coiiticioiik are prevalent throughout all the units. Paleontological finds at JPC are significant for hiostr.iti~:r.il)hic. analyses; however, predicted finds are not anticipated to be unique or unusual.

J.3.1.5 Soils

JPG is dominated by two major soil associations: the Cobbsfork-Avonburg Association and the Cincinnati-RossmoyneHickory Association. A combination of different soil types occur on or adiiccnt to stream beds (Figure J.3.l-5). These soils include Ryker, Grayford, Holton, Eden, Elkinsville, and Wirt soil types. The soils of JPG originate from glacial till and outwash, lacustrine deposits, limcstonc and shale residuum, windblown alluvium and loess. The soils are strongly weathered, leached and ,iL.idic. The soil fertility at JPG is low (USACE 1988). There are known and suspected releases of contaminants to soils on JPG which are discussed in Section J.3.4.5 (USATHAMA 1990). The characteristics of soils occumng on the property of JPG are summarized in Table J.3.1-1. The locations and extent of thr general soils associations are identified in Figure 1.3.1-5.

J.3.1.5.1 Cobbsfork-Avonburg Soil Association

Cobbsfork-Avonburg soils occupy more than 40 percent of the JPG. These soils are nearly level, with slopes ranging from 0 to 4 percent, and are found in the upland areas of the installation. Soils of the association are deep, and poorly to somewhat poorly drained. Slow permeability and a seasonably high perched water table (December through April) pose severe limitations to development. The Cobbsfork and Avonburg silt loams are severely limited as sites for roads and dwellings and are unsuitable for septic tank absorption fields (USDA 1985).

J.3.1.5.2 Cincinnati-Rossmoyne-HickorySoil Association

Cincinnati-RossmoyneHickory soils are found on gentle to moderately steep slopes alon~the drainageways of the installation. The soils are deep, moderately to well draincd, and havr slow permeability. Extreme wetness, poor porosity, and steep slopes make these soils less dcsir,iblt~for

development than the Cobbsfork-Avonburg soils (USACE 1988). Occasional flooding and~ erosion arcs

3-8 Ollcr Crcck Lilllc Oller Creek

t N H 0 mi. lmi.

LEGEND 0Cobbsfork-Avonburg Cincinna ti-Rossmoyne-Hickor y

Combined soil types (streambeds) . Headquarters

Figure 1.3.1-5.Soil associations of the JPC

3-9 I I l

3-10 3-11 hazards which are characteristic of this association. The Cincinnati-Rossmoyne-Hickory silt loams are severely limited as sites for roadways or septic tank absorption fields (USDA 1985). Cincinnati so:' make up approximately 24 percent of the association, 18 percent are Rossmoyne soils, and 14 pcro are Hickory soils. The remaining 44 percent of the association are soils of minor extent (USDA 1085).

1.3.1.5.3 Combined Soil Types

The soils of this group, which includes Ryker silt loam, Grayford silt loam, Holton loam, I4cn silly clay loam, Elkinsville silt loam, and Wirt silt loam are located on or adjacent to strcsam bds. SIW~ slopes, erosion and flooding represent the main limitations for most types of devclolmient. Development on these soils is not recommended (USACE 1988). The Elkinsville, Ryker and Wirl soils are considered prime farmland, and Holton soils are prime farmland where they are drained (LJSI>A 1985).

J.3.1.6 Water Resources

J.3.1.6.1 Groundwater

Groundwater in the vicinity of JPG is primarily stored in Silurian and Devonian limestone aquifers. The Brassfield Limestone is the principal aquifer underlying JFG. Primary porosity of this compict crystalline unit is very low, and secondary porosity from fracturing and subsequent solution is poor' developed (USATHAMA 1989). The limestone aquifers in this region are confined by the overlyin,, finegrained glacial material. Well depths range from 50 to 250 feet and yields range from 10 lo 100 gallons per minute (gpm) (US.Geologic Survey WSGS] 1985). Groundwater from Silurian-Dcvonian aquifers is, in general, hard and may have high sulfur content.

A USGS monitoring well, located immediately south of Family Housing, has a well depth of 200 feet and is drilled on a mapped fracture trace. Water levels ranged from 4.25 to 7.78 feet below the surlacr in water year 1986-87 (USGS 1987). Yields from this well are not documented. Predicted average yields for Silurian-Devonian limestone aquifers are less than 25 gpm. In general, these aquifers are poor sources of groundwater (Bloyd 1974). Glacial deposits can be good sources of groundwater, howevcr, glacial till is a poor aquifer due to the abundance of silt and clay sized particles. There is no sustained groundwater flow in the glacial till at ]PG (USATHAMA 1989).

The water supply for JPG is obtained from the Madison Municipal Supply System and Caanan Water System. Average daily and maximum usages at JPG are 60,000 and 150,000 gallons rcspecllvcly Uoshi 1990). The Madison Municipal System has several wells tapping the aquifer underiicalh I\>(, Ohio River. There are no on-post wells used for water supply (see also Scytion j.3.4.5.13). -

3 - 12 There are no comprehensive groundwater quality monitoring programs at JPG. Monitorin); wdls were first installed around the Gate 19 Landfill in 1982. Sampling results from 1982 and 1983 sl1owe.d low levels of volatile organic compound (VOC). No Voc's were detected after April 1984. It was determined that these early sample results were inconclusive regarding ground water quality and flow direction. Consequently, a remedial investigation of the Gate 19 Landfill and the solvent disposal iirms was undertaken. Additional wells were installed around the Gate 19 Landfill and three wells were installed around Bldg 279. Those monitoring wells that exhibited contamination exceeding detrclion limits or Federal criteria have their locations shown in Figure 1.3.1-6.A summary of significant findings of the groundwater analysis is presented in Table J.3.1-2. The indicated wells were used for waler quality analysis only; pumping rates and flow rates of the wells are not documented. Groundwater velocity in the vicinity of the Gate 19 Landfill and Building 279 are 15 feet/year to the west-nortliwest and 2.92 feet/year to the south-southeast, respectively (USATHAMA 1989).

In general, known groundwater contamination is localized at the landfill and solvent disposal areas (see also Section J.3.4.5Active and Abandoned Landfills and Solvent Disposal Areas) (USAT1 IAMA 1989). Tests of groundwater monitoring wells haveshown that the groundwater flow ratesare very low and that any contaminants that may be present have not migrated to the downgradient wells. 'l'hcrr are also other suspected releases of contaminants to groundwater. Potential sources of groundwater contamination include other solvent disposal areas, other solid waste landfills, unexploded ordnance (UXO), the Depleted Uranium (DU)Impact Area, red lead (lead oxide) disposal areas, bum areas, and underground storage tanks (USATHAMA 1990). There is insufficient data to assess the extent of on-site groundwater contamination (USATHAMA 1990).

J.3.1.6.2 Surface Water

JPG lies within the White River Basin which is a sub-basin of the Wabash River Basin (a sub-basin of the Ohio River Basin). Six major streams of the White River Basin cross JPG in a northeast to southwest direction (Figure 1.3.1-2 and Figure J.3.1-6). A small section along the southeast perimeter of the installation drains more directly into the Ohio River; however, no tributaries in this sub-basin are crossed.

The southernmost stream on the Installation is Harberts Creek, which drains approximately 6,l IU acres of the JPG property. The sanitation plant for JPG is located on this stream. Krueger Lake occupies 8 acres of the Harberts Creek drainage basin. The main branch of the stream is permanent and is fed by two intermittent tributaries, one of which originates at Krueger Lake. A USGS gaging station on Harberts Creek near Madison, IN, records an average discharge of 13.0 cubic feet per second (cfs) (USCS 1987). The extreme discharge at the station in 1987 was 707 cfs, and the maximum discharge for the period of record (1968 to the present) was 1,540 cfs which occurred on April 2, 1970. .

3-13 Figure J.3.1-6. Groundwater quality monitoring wells at Gate 19 I.andfill and Bldg. 279 - solvent disposal area.

3- 14 3-15 The headwaters to Middle Fork Creek are on the eastern boundary of the JPG proprrty. Stww’ unnamed, intermittent tributaries feed the main branch of Middle Fork Creek. The creek has a p,rcivt-la, substrate and drains approximately 6520 acres of JPC.

Big Creek drains approximately 11,460 acres of JPC. The creek is characterized by a deeply inriwd, meandering channel with a sandy and gravelly substrate. Numerous interniittent and pcminncwt streanis which are tributary to Big Creek originate on the installation. The largest of thest, i.; Marhlc Creek, a permanent stream with rocky substrate and a relatively straight channel through thr liiiit~stoii~~ bedrock.

Little Graham and Graham Creeks are deeply incised permanent streams with gravelly siibstr,itcs. Both streams originate off of the JPC property. Little Graham Creek, a tributary to Graham Creek, drains an area of JPG of approximately 7,760 acres. Graham Creek drains approximately 5,870 ncrc‘s of JK.

Otter Creek is the northernmost stream at JPG, draining an area of the installation which is approximately 10,690 acres in size. Little Otter Fork, a major permanent tributary to Otter Creek, originates at Old Timbers Lake and is confluent with Otter Creek near the northwest corner of JK;. Old Timbers Lake occupies approximately 165 acres of the Otter Creek drainage basin. Otter Creck and its tributaries are deeply incised into and meander through the underlying limestone.

There are no formal monitoring programs for surface water quality at JPG, with the exception of the National Pollutant Discharge Elimination System (NPDES)program at the sewage treatment plant and the DU area monitoring program. Occasional studies performed by the U.S. Army Environmental Hygiene Agency (USAEHA) and the Department of the Interior did not include analyses of substances, other than lead, which might occur as contaminants from JMZ operations. Therefore, there is not enough available data to assess the surface water quality.

The NPDES Permit was issued to the Department of the Army JPC on April 15,1974. Citations for violations of the NPDES Permit for total suspended solids have been issued by the U.S. Environmcmtal Protection Agency (USEPA) in March 1978, March 1979, and January 1980. Continued violations of standards for total suspended solids (15 mg/l weekly average and 10 mg/l monthly avcrage) necessitated design changes. The 28,000 linear feet of leaking vitrified clay pipes were replaced in March through September, 1989 by PVC pipes. This has brought the plant back in compliance with the total suspended solids limit of the NPDES permit. Before this construction, the plant influent excrvdcd its treatment capacity and often violated the total suspended solids limit. The plant iievcr violakxt otlicr

3- 16 permit limitations. The state has now issued a new NPDES permit effective through August .I995 (Joshi, personal communication, 1990).

There are suspected releases of contaminants to surface waters, The potential soiirccts of contamination include cracked UXO, the DU Impact Area, red lead disposal areas, burn mm, and ~hc. sulfur disposal area (USATHAMA 1990). Runoff from soils treated with herbicides and pcstiric1t.s imy also be a source of potential surface. water contamination (Indiana Department of I~nvirciiirnci~t~I Management [IDEM] 1989). The potential for these releases arises from the proximity of sevc’r.11 c rwks to various impact and bum areas.

Currently, the streams crossing the JPG installation are not part of the National Wild and %wir River System. Nor do the streams have any segments listed in the Nationwide liivers Invcntory (Medlend, personal communication, 1990).

J.3.1.7 Aquatic Resources

Baseline information obtained for this section is from personal contacts with state and Fedrral agencies and review of available maps and literature. Unless otherwise noted, the fisheries information presented here is primarily a summary of a 1980 report prepared by the U.S.Fish and Wildlife Srrvice and the US.Department of the Interior titled Fisherv Management Plan (Clesne 1980). No studies or field investigations of any kind have been performed on benthic invertebrate communities in Ihc rqion (Lauer and Winters, personal communications, 1990).

As described under Water Resources, six stream comdors cross JPG from a northeastern to southwestern direction. A majority of these streams are classified as low order because of their proximity to the headwaters. Additional aquatic habitats include numerous ponds, lakes and impoundments scattered throughout the base. The smaller ponds include several abandoned quarry pits which are about four acres in size and bamer dams with areas generally under two acres (USACE 1988).

Fish surveys of several of the ponds, including Krueger Lake and Old Timbers Lake, have resultid in the identification of at least 12 species. These include sunfish (Lepomis spp.), bass (Micropterus spp.), and catfish Uctnlumts spp.). The smaller ponds have been managed in the past for bass, bluegill and catfish. Sport Hsh at Krueger Lake include bass, bluegill, sunfish and channel catfish. Harvest records for Old Timbers Lake include bass, bluegill, sunfish, catfish, black crappie (Pornoxis nipronracukrlus) and walleye (Stizostedion vitreum). Most of these species have been stocked at least once in scwer,il of 11,e ponds and both lakes. Reported standing crop production ranges from 100 to 300 pounds pr.ICW

3 - 17 Of the nearly 90 miles of permanent and ephemeral streams, a majority are rcstrictrd bi*.c..iiisc. of their location within the testing ranges and the presence of UXO. Stream survey rccords exist only (0- the Otter Creek corridor. However, the other streams are reported to have sport fishes and receive soin fishing pressure along the western edge of the installation.

For Otter Creek and its tributaries, 28 fish species were collected in the 1980 survey. Inrludcd among these were gar (Lepisosteus usseus), shiners (Notropis spp.), sunfish, bass, bullhead (Ictnlitrirs spp.), darters (Etheosfoma spp.) and others. No Federal or state endangered, threatened or rnrr fish sprcics have been reported in Otter Creek within the boundaries of the post. However, now ol \hi* t)tlii*r streams have been surveyed within JPG. One fish species, the Eastern Sand Ilarler (Anriirocypf pellucida), a future candidate for Federal endangered species status, is found in Jeffcrson County str(iiini habitats (USACE 1988) and could occur on the JPG. USEPA biologists also have collected the harluliiin darter (Etheostoma histrio), a species thought to be extirpated from Indiana, in Graham Creek just wrst of JPG near San jacinto.

Although no studies have been performed, potential influences on aquatic biota from hiiimn activities do exist on the installation. These activities/structures include: the Gate 19 landfill locatid in the southwestern comer of the base near a tributary to Middle Fork Creek; munitions exploding in thc impact zones leading to possible erosion; past practice (before October 1986) of open burning on the ground of excess propellants in the southern end of the base (Joshi, personal communication, 1990); open burning of scrap wood in the southern part of the base; and, the use of pesticides and herbicides All mentioned activities are performed under Federal guidelines with safety procedures and mechanism.. in place (USATHAMA 1980).

The primary source of any potential effects from the activities is runoff after periods of rainfall. Soils adjacent to stream beds are subject to greater erosion than other soil types present on the JPG (USACE 1988). Those streams within impact zones could receive sedimentation loading from erosion accelera tcd by exploding ordnance.

J.3.1.8 Terrestrial Ecology

This section summarizes the major terrestrial ecological features of JPG. The summary includes information concerning vegetative land cover, wildlife typically associated with each cover type, and existing knowledge of endangered species. Due to the nature of the mission at JPG, the properly has never been systematically inventoried. Terrestrial information provided is based on available data, expert opinion, and limited surveys.

3 - 18 J.3.1.8.1 Wildlife

Wildlife species on the JPG are both abundant and varied due to the combination of covvr Iyprs such as mature and immature hardwood forest, mature pine stands, open fields, scrub-shriib/olti hid, wetlands and riparian corridors. Common wildlifespecies and their associated habitats are siimniiirixed in Table 1.3.1-3. Comprehensive species lists for mammals, birds, reptiles and amphibians are prwkicd in Appendix D. Wildlife species likely to occur in the project area are described below.

Mammals

Within JFG and the immediately surrounding area, 50 species of mammals are known or likcly lo occur (Appendix D) (Burt and Grossenheider 1976). Of these 50 species, the opossum, raccoon. stripcd skunk, beaver, woodchuck, fox, eastern gray squirrel and whitetail deer are most commonly sccn on the Proving Ground (USACE 1988; Knouf, personal communication, 1989).

A number of mammals such as the whitetail deer, fox squirrel, eastern gray squirrel, and eastem cottontail are harvested within the JF'G. Hunting of these species on the installation is available to JlC employees and military personnel and their guests, and a small number of drawn State hunters, on a strictly controlled basis (USACE 1988). Areas where controlled hunting is permitted arc depicted in Figure J.3.1-7.

According to the JK Natural Resource Manager, approximately 700 to 850 whitetail dcw arc harvested annually (a total pre-hunt population of 3,500 to 5,500). These harvest levels make the whitetail deer the most important game species within the Proving Ground. Prehunt population estimates from 1983 through 1988 ranged from 40 to 66 deer per square mile (Feldt 1987). This density is two to three times higher than the densities calculated for the surrounding counties. Due to the large deer population on the installation, the Natural Resource Manager initiated a comprehensive deer management plan. The plan was to be included in the comprehensive Five Year Natural Resource Management Plan (''Natural Resources-Land, Forests, and Wildlife Management"). However, only the Forest Management Part III) portion of the plan has been completed. The Army will prepare a Natural Resources Management Plan that will address natural resource concerns at JX.Wildlife concerns will be addressed in this plan.

The Forest Management Plan does, however, incorporate wildlife needs into its overall forestry plan. Deer and rabbit browse is created by cutting big tooth aspen (Populus grandidenfafa) that prorlurc~ prolific stump sprouting. Designated mast producing trees such as hickories (80 Cnrya spp.), American beech (Fagus gmndifolia) and oaks (Quercus spp.) remain uncut. Thwe nut-bearing trees produce important foods for species such as whitetail deer, wild turkey, easlem gray scpfirrc-1and

3-19 I

3 - 20 hl

. I 0 mi. 1 mi

LEGEND

Restricted area (no hunting and fishing)

Controlled hunting (small game, gamebirds, and dccr hunting with a bow only 0Controlled general hunting arm (available to JPGemployees and P’G-sponsored guests on a rcstrict- ed, permit-issuing basis only)

Timber harvest/controlld general hunting arcas

Headquarters

Figure J.3.1-7. Controlled natural resource areas of the JPG (July 1989).

3 - 21 wood duck. At least two "cull trees" per acre are left in the timbered areas. Small (3 to 5 acrc) openings also are cut in the mature forest areas. These open areas produce prolific vegetation sprouting iis wcll as provide a variety of wildlife habitats.

-Birds

JPGand the surrounding area has a diverse avian community (Peterson 1980; National Chipxpliic Society 1983; Keller et al. 1986). A total of 121 avian species have been reportcd to use thr iimi within and surrounding the installation for breeding purposes. The remainder of the bird sptrirs occiir ciiiriii~; migration or as winter residents. The rich avian diversity is expected due to thr virrious covt'r typrs (such as mature and immature hardwoods, ecotonal areas and wetlands) found on the l'roving ( ;niiintls. Due to favorable habitat conditions, JPG supports an abundant population of bluebirds ;inti two bluebird trails have been created at the installation. Cover types and the associated bird species expected to occur within the installation are summarized in Table J.3.1-3. A complete list of hirds that occur in the JPG region is presented in Appendix D.

Important upland game birds in the area include the wild turkey and the northern hohwhite. During the late 1970's, 13 wild turkeys were released on the JPG with the help of thc Indiana Department of Natural Resources. Presently, the wild turkey harvest ranges from 12 to 41 hirds, during the annual eight day hunting season (Knouf, personal communication, 1990).

Reptiles and Amphibians

The reptiles and amphibians, whose geographic range encompasses the project area, include seven species of turtles, three species of lizards, sixteen species of snakes (includes two poisonous species), eighteen species of salamanders, three species of toads and twelve species of frogs (Appendix D) (Conant 1975; Karns 1986; Minton 1972). Karns (1986) reported that JPGs Graham Creek (mature hardwood forest habitat with an associated creek) was the richest herpetological site found in Ripley County Figure J.3.1-8). The remaining herpetological sample stations, within the installation, also are depicted on Figure J.3.1-8.

Suecies of Concern. Threatened, and Endangered Wildlife

Due to the nature of the installation's mission, JFChas never been systematically surveyed by the Indiana Department of Natural Resource staff biologists, Federal US.Fish and Wildlife Service (USIWS) biologists, or others; therefore, critical species accounts or other abundance estimates are lacking for the installation. An initial field survey for the bobcat was conducted at JPG tlowevcr, datn pillrcwd froin this survey was inconclusive. A survey for the Indiana bat is in the early planning stiigcs. I'liins 11)

3 - 22

.. . .- LEGEND

Herpetological sampling sitcs:

@ Maturvwtmis Rare natural cornrnunitics:

Potential am

El Potential area Potential area

Great blue heron rookmy zti 'C Creek 2 3

Krueger Lake

Figure J.3.1-8. Location of herpetological stations and unique and rare natural areas of the JPC. 3-23 conduct surveys/research in 1991 on the Indiana bat and bobcat are being developed hy JI’G iindvr its non-game management program. Several Federally endangered species are known to mist 111 th immediate vicinity of the property. These species are subject to protection providcd ui1dc.r tlic Endangered Species Act of 1973. Five Federally endangered species may occur within the JlY; propcrty boundaries (four birds and one mammal) (Hudak, personal communication, 1989; Whitaker ct ‘11. IYHH; Bracket al. 1989) (Table 1.3.1-4). The habitat of the Indiana bat does potentially exist within JI’G. ‘l’liiw are no Federally listed threatened species known to exist or occur within the ]I< bnundarics. ’l’hi, Kirtland’s water snake is a listed as a “Category 2” species (status of species under Federal rwi(,w for possible listing) (USFWS 1989).

There are 22 Indiana State endangered species known to exist or occur in the immediate vicinity of the JPG property (eighteen birds, two mammals and two amphibians) (Indiana Depirtment of Natural Resources 1988; Webster, personal communication, 1989; Whitaker et al. 1988; Karns, pimonal communication, 1989; Minton 1972) (Table J.3.1-4). These species are subject to protection provided under Indiana Law 310 3.1-2-7. Indiana State threatened species known to exist or occur ill the immediate vicinity of JPG include two birds, one mammal, two amphibians and one reptile (Minton 1982; Kams, personal communication, 1989; Karns 1986; Hudak, personal communication, 1989; Martin, personal communication, 1989). A complete list of State species of concern is provided in Appendix I:.

Indiana State species of concern known to exist or occur in the vicinity of JPG include thirteen birds, and two mammals (Table J.3.1-4) (Keller et al. 1986; Karns, personal communication, 1989) JI’C supports a great blue heron colony (State species of concern) of over 150 nests which has been protrcted since its discovery. The rookery is located on Graham Creek in the southwest quarter of Section 35, T7N, RlOE on the Holton Quadrangle (Figure J.3.1-8) (Hudak, personal communication, 1989).

J.3.1.8.2 Vegetation

Land use changes and practices since the late 1800s have altered or disturbed much of the natural vegetation. Prior to Army ownership in 1940, the land was primarily farmed (Glesne 1980; TECOM n.d.) for sorghum, tobacco, corn and wheat and the wood lots were harvested for the larger trees (USACE 1986). To achieve its primary objective as an ammunition testing facility, alterations in the vegetation were made, which included: pesticide application CTECOM 1978); herbicide and soil sterilant applications for clearing; logging and prescribed burning in select areas; physical damage to trees from ammunition testing (Glesne 1980); and metal contamination of the soil (USACE,1986). Natural disturbances include blowdowns, tornado damage, and insect damage to trees. Annual surveys for gypsy moth detection have been conducted since 1983 (USACE 1986).

3 - 24 X

X xxxxx

X xxx

3-25 X X

xxxx xx xx

3 - 26 In spite of these alterations and disturbances to the land, the majority of acreage within JIY; is comprised of natural vegetation communities. Approximately 97 percent of the installation is undeveloped, and Serves as operational and industrial land uses, the safety zone, and the lest rang(' (scc Section 1.3.4.5.3, Land Use). The remaining three percent of the Proving Ground is developed and has been landscaped CTECOM 1978).

Cover Tvws

Land cover classifications were identified from an analysis of Landsat multispcclral digitail if.ita processed from film taken in the spring of 1977 (USDA 1978). The classifications reported wiw btistrl on available US. Geological Survey topographic maps, since ground-truthing was not pos~ibli* Therefore, some discrepancies exist between the interpretation of the photographs and actual land IISC Although the information is dated, land use at JPG has not significantly changed over the last drcade (Knouf, personal communication, 1989). The three major classes of vegetation identificd within JIY; are brush, forest and wetland. The other classifications reported are: barren, semi-barren and water

Barren areas are devoid of vegetation due to artillery impact, machinery use, and herbicide application. The airfield runways and bare soil associated with impact zones are barren. Semi-harren areas have minimal ground cover such as the developed areas with intensely mowed fescue lawns in the southern portion of JPG.Barren and semi barren areas account for approximately 1,139 acres within JPG. Large, open bodies of water and wide sections of streams were classified as approximately 116 acres of water (USDA 1978a).

The classes Brush 1 and Brush 2 include late successional fields with young saplings and some trees. Brush 1 (7,289 acres) is defined as having slightly less vegetation cover than Brush 2 (13,574 acres), and for subsequent discussion, these categories are referred to as Brush. Open fields surrounding wooded areas are primarily reseeding to sweetgum and red maple (TECOM 1978). Types of ground cover include poison ivy, blackberry, honeysuckle and others (USACE 1988).

Forest land includes areas of dense woodland, such as the large area northwest of the airport and the area north of K Road. Estimates of forest cover differ according to definition. The Iandsat classification scheme estimates 24,670 acres of dense woodland (USDA 1978). An EIS revised in 1980, reports 43,593 acres of forest (TECOM 1978); and the USFWS estimates that 35,000 acres are heavily forested (Hudak 1989). The significant difference in reported acreages is apparently due to inclusion of wetland acreage in the total. The estimate of forested acreage has probably increased as old fields revert to sapling stands. An updated comprehensive inventory assessing the various resourws on thv installation is not available.

3 - 27 The most abundant species on JKis red maple which is associated mainly with tIic* we~liinil.irviis.

White oak and yellow poplar dominate on the northern end of JPC whilc rcul cvdar I~ri’doiiiiii;it[.s; well drained areas (Knouf, personal communication, 1990). Less dominant and locnlly dominant sp*cii*a of hickory, pin oak, red oak, sweetgum, beech, elm, ash, sugar maple, sycamore, walnut, black clwrry, and sassafras also occur (USACE 1988; TECOM 1978). A list of common vegelation species that Iiavc been identified on JK can be found in Appendix F. Contrary to the landsat computer enhanced characterization, very little coniferous forest is present. There are approximately 60 acrcs of whilc pine along the K road in the north west of Old Timbers Lodge. Because of past logging prncticrs, tlwrc arc large variations in timber stand size classes and densities (USACE 1986).

Wetlands are located along stream corridors, on fringes of lakes, in forests, and in wrt drprc~wons in fields. Wetlands identified from landsat images include areas of water and vegetation, sucli .\s thv area of extremely wet soil between Big Creek and Fork Creek. A total of 6,376 acres of wetland\ were estimated to exist in the area based on landsat images (see Section J.3.1.8.3).

In addition to wetlands, other areas of special interest exist within JPG (Figure J.3.1-8). l’hc Indiana Department of Natural Resources (IDNR) has identified three areas with excellent natural coniniunily values. The coordinates for these sites are: Rexville Quadrangle in the NE 1/4 of the NE 1 /4 of Scsction 14, T6N, RlOE; Holton Quadrangle in the NE 1/4 of the SW 1/4 of Section 17, Ti”,RIOE; and I lollon Quadrangle in the SE 1/4 of the NW 1/4 of Section 18, T7N, RIOE. These areas were identified from aerial photography by the IDNR,and have not been ground-verified (Hudak, personal communicalior 1989; Martin, personal communication, 1989).

Although not indigenous to the area, a small grove of bald cypress, believed to have been planted by a previous landowner, grows south of H-Road. The trees grow in the east central area of the testing range, and have therefore been adversely impacted by test firing operations (USACE 1988).

Land Manaeement Practice

The major land management activities performed at JPG include prescribed burning and 1o);ging. To maintain areas as open fields, burning followed by strip planting of grasses and legumes is priicticed (Glesne 1980). Approximately 10,000 to l5,WO acres per year are burned, resulting in young brush growth. JPG does little seeding or planting after prescribed burning. Normally, a variety of native and exotic vegetation resprout quickly. This variety of vegetation provides browse for wildlife. Mowing occurs twice yearly in semi-improved areas when seed formation is complete (TECOM 1978). Soil sterilants such as Bromacil,’.2-4-D, 2,4,5T have been used in the past for clearing of impact zoncs. Herbicides including Roundup and Arsenal are currently in use (Joshi, personal communication, ‘1989).

3 - 28 Herbicide usage has been heavy at fields designated as improved conventional munitions (ICM) impact fields (16,000 east, 16,000 west, 16,000 center, and 22,000 center). This is because of the nccc-ssity of recovering the submunitions from the ICM rounds. These submunitions, because of their sninll sim, can be obscured easily by vegetation (IDEM 1989).

The herbicides of most concern in terms of their toxicological properties are 2,4,5-T and 2,441 ('l'able 1.3.1-5). Both have limited evidence as to their carcinogenicity but are toxic at low dosr~. Ihth compounds are considered hazardous waste constituents. The last use of these conipniinils iil IIY; was in 1980. Bromacil was used after this period of time. Soil samples from two impnct fields sliowiul residual levels of Bromacil. Stream sediment samples were collected from all the major streams cniwiril; JFG.Vernon Fork of Otter Creek and Middle Fork showed trace levels of Bromacil. No other pcslicides or herbicides, including 2,4 D and 2,4,5,T were detected in any of the sediments. It is not known what residuals exist in surface water, ground water or soils in impact fields which were not sampled altlioiigh some residual is expected (USAEHA 1983a).

Timber is harvested north of K Road and in the south end and along the perimeter (Figure J.3.I-7). Approximately 15,000 acres of timber have been harvested since 1941 (IDEM 1989). These harvests include saw timber and high quality veneer (TECOM n.d.) of white oak and black walnut (USACE 1986). By-products include hardwood pulpwood, firewood, and fence posts from red cedar and black locust.

Annual timber sales have been regulated and controlled since 1982 when the responsibility for timber disposal was transferred to the Louisville COE District. Annual harvests historically have mnpd from 300,000 to 400,000 board feet. It is estimated that 442,ooO board feet is the annual allowable cut to achieve a sustained yield, the level at which removal is equal to growth (USACE 1986). Increases in the allowable cut are expected if the harvests continue over the next ten years. The recommended harvest rate for the ten year period 1986 - 1996 is 4,424,397 board feet (USACE 1988). The estimated board feet available north of K Road is 30,000,000.

There are approximately lo00 acrs of forest available for commercial use, that are not currently being logged (USACE 1986). Many other areas are forested, but not available for commercial harvesting (USACE 19%). A 1986 inventory of the forest on the north end of JPG listed 46 tree species, all but six of which are considered marketable. Management practices allow for the growth of valuable species, such as black walnut, white oak, northern red oak, green ash and yellow poplar. The amount of board feet harvested by species is given for the 1988-1969 season in Appendix C.

Very little tree replanting has occurred within JPG, primarily because the deer tend to browse on young seedlings (USACE 1986). Reseeding occurs primarily by natural revegetalion. Iiowcvcr, in

3 - 29 Table 1.3.1-5. Historical (1980) use of insecticides and herbicides at JTC.

Concentration Approximate Herbicide/Pesticide used Annual Use Target Species

Aquatol 30.3 lb/acre 30.3 lb Lake and pond wecdls Copper Sulfate 3.6 Ib/acre 10.8 Ib Filamentous algae in lakes

Atratol 436.0 Ib/acre 33.0 tons Coarse weeds along roads and railroads

A tra to1 436.0 Ib/acre 6.5 tom Coarse weeds in recovery areas

2,4-D + 2,457 10.0 gal/acre Approximately Coarse weeds in 5,610 gal recovery areas

2,4-D + 2,455-T' 10.0 gal/acre 690 gal Coarse weeds in fire lanes

Rotenone as needed as needed Rough fish as advised by Do1 biologists

Anticoagulant 1 part added to 54 Ib Mice Concentrate 9 parts dry bait

Dursban @ 1 gallon/1,000 2,200 gal Roaches S9ft Pyrethrins 2 to 3 fled 4,000 cu ft Flies 1,000 cu ft

Malathion 1.5% at 0.2 to 130 gal Mosquitoes 0.5 Ib/acre

Malathion 2% at 1 gallon/ 192 gal -- 1,000 sq ft

'Use of 2,4,5-T suspended in response to emergency order by EPA Administrator Douglas M. Costle on February 29, 1979.

SOURCE IDEM 1989

3-30 1970/71, 4,000 walnut seedlings were planted (TECOM 1978; USACE, n.d.). Improvement of timh?r stands occurs by controlling grapevines and cull tree removal.

Swcies of Concern. Threatened. and Endangered Flora

Several State of Indiana listed plants and one Federal endangered plant potentially occur within the confines of JPG. JPC is within the range of running buffalo clover (Trijolium sfoloniftwnr), a Federally listed endangered species subject to protection provided under the Endangered Spcries Act of 1973 (Hudak, personal communication, 1989). The smooth white violet or red stem violet (Viola blanda), a State designated threatened species occurs within the boundaries of JPC (IDEM 1989; Martin, personal communication, 1989). The IDNR is currently planning to conduct a literature survey in the winter of 1991/1992 followed by a field survey in the spring for endangered and/or threatencd species.

J.3.1.9 Wetlands

Wetland resources were investigated through the use of the USFWS Draft National Wetland Inventory (“1) Maps dated March, 1986. A IMot per inch grid was used to estimate the acrcagvs of the major wetland types. Six broad categories of wetlands are identified within the JI’G impoundment. According to the NWI classification system (Cowardin et al. 1979), the six types and their recognized designations are as follows: Palustrine Forested PFO); Palustrine Scrub-Shrub (15s); Palustrine Emergent (PEM); Palustrine Unconsolidated Bottom (PUB); Riverine (R); and Lacustrine (L). In addition to acreage, wetlands associated with streams were measured in terms of lincar distance because stream widths were narrow and did not provide an area that could be measurcd.

Acreages and linear distances for the six major wetland types are as follows:

mil?s&d Linear Miles BroadDesc rintion

PFO 2,090 5.0 Dominated by broadleaf, deciduous, woody, vegetation, 6 meters tall or taller; 30% aerial coverage.

pss 632 Dominated by young specimens of lhose in a PFO wetland or species that will remain as shrubs, less than 6 meters tall.

PEM . 28 0.75 Exist where disturbance sufficient enough lo negate formation of successionally nominl 1’I:O.

3-31

. -_ PUB 34 Less than 30% vegetation cover; lark stiihle bottoms.

R 14 63.0 Usually includes all wetlands within a clianric.l with flowing water.

L 165+ __ Permanently flooded lakes and reservoirs, intermittent lakes; lack Vegetation with mort* than 30% aerial coverage.

Total 2,963+ 68.75

Three major wetland complexes are concentrated on the eastern side of the base. One coniplc~xis associated with headwater streams of Little Graham Creek and accounts for 480 acres of 1'10 and 1% wetlands. Another complex is associated with the headwaters of Marble Creek which empties into I3ig Creek. This complex accounts for 524 acres of PFO and PSS wetlands. The third complex is assoriatrd with one of the headwater streams of Big Creek just inside the eastern boundary of JIGand accounts for 175 acres of PFO and PSS wetlands. Together these wetland mosaics account for 40% of thc total 2,963+ wetland acres estimated using the Draft NWI maps.

A second estimate of 6,376 wetland acres was obtained from the General Electric Company's (US131 1978a) classification and enhancement of Landsat data. Wetlands were defined as land cover where a mixture of water and vegetation existed. The verification performed during the classification of the Landsat data consisted of review of USGS topographic maps and consultation with JPG personnel. No field ground truthing was performed.

The difference in estimates between the two methods of mapping highlights the shortcomings of determining land cover without ground truthing through field investigations. The validity of both sets of data could not be field checked due to activities related to the mission and the hazards of UXO. Other possible reasons for a discrepancy in the acreage amounts include: the two sets of dah were obtained approximately nine years apart; different individuals of different skill levels and training performed the data interpretation; and, the NWI maps are drafts that have yet to be finalized. Therefore, it is estimated that there are at least 2,906 acres on the JPG site, but possibly as much as 6,376 acres. The actual total acreage may even be found to exceed 6,376 acres if field verified.

3 - 32 J.3.2 AIR QUALITY

The status of air quality was determined by a comparison of observed concentrations of j:ivrn pollutants with corresponding limits listed by the ambient air quality standards of the gcivmmini; St,ltc. Implementation Plan (SIP). The following are the pollutants of concern:

Sulfur dioxide (5022: 502 is emitted principally by space heaters, power plants, industrial processes, and internal combustion engines. It can irritate the respiratory tract and cniisc chlorosis in plant leaves. In moist air and sunlight, it forms acids that damage vep,tatit~~i and structural materials.

Carbon monoxide (Ca:CO is emitted by internal combustion engines and cvrtiiin industrial processes. It is not an irritant and has little or no effect on plants or matrriais. However, it reacts in the blood stream to deprive the heart and brain of oxygen. tiii;h Concentrations can be lethal.

Oxides of Nitroeen (NOxl: Oxides of nitrogen are formed by high-temperature combustion in both stationary and mobile sources of, mostly, atmospheric nitrogen. The principii constituents are nitrogen dioxide (N02)and nitrogen oxide (NO). NO reacts with certain organic compounds in the atmosphere to both generate and destroy ozone and N02. In higher concentrations, nitrogen oxides injure vegetation, cause deterioration of fabrics and dyes, contribute to metal corrosion, and may affect lung tissue and reduce resistance respiratory disease.

Ozone (03): Ozone is not an emitted pollutant but is formed by a complex series of reactions involving nitrogen oxides and certain organic compounds in the free atmosphere under the influence of solar ultraviolet radiation. Ozone is shorter-lived than its precursors, which may build up and redistribute geographically over an extended period of air stagnation. Ozone causes eye and respiratory irritation as well as reduced lung function, is toxic to many plants, and weakens such materials as rubber and fabrics.

Suspended uarticulate matter Partiadate matter consists of dust, smoke, and other solid and non-volatile particles small enough to suspend readily in air. Particulate matter, mostly of small diameter, has been associated with increased respiratory symptoms and illness, and at very high concentrations has been known to produce premature mortality in the ill and elderly. The July 1, 1987 Federal Register announced a revision to the standard for particulate matter with a new indicator that includes only those partick-s with a11

3 - 33 aerodynamic diameter of 10 microns (micrometers) or less, designated as Particdiik matter,lO microns or less (PMlO).

Lead (Pb): Lead is emitted into the atmosphere by vehicles burning leiic1L.d fuel anti hy certain industries. Airborne lead is associated with particles ranging between 0.1 and 5.0 microns in diameter. Lead interferes with the blood forming system, the nervous syskni, the renal system, vitamin D metabolism, and can affect the normal functions of tlic. reproductive and cardiovascular systems. Low levels of lead absorption by young childrw can cause permanent mental retardation.

Current stationary sources of on-post emission include three boilers powered by fuel oil, the sttwage treatment plant and a multiihambered incinerator with an after burner. Open burning ol (txccw propellants and detonation of explosives, and fire fighting training also are emission sources. Exploding ordnance during testing activities and normal vehicle use are mobile sources of pollutants.

J.3.2.1 Ambient Air Quality Standards

In accordance with Rule 3 of the Indiana Administrative Code 326, which lists the Amhicmt Air Quality Standards for the State of Indiana (326 IAC 1-3-4), the standards for the State are idcnticnl to the Environmental Protection Agency (EPA) National Ambient Air Quality Standards (NAAQS) that arc currently in effect (1989) Appendix H. Primary and secondary standards are in effect for tlie sir pollutants previously described. Primary standards relate to the protection of public health, whilt secondary standards are intended to protect the national welfare as measured by pollutant effects on animals, vegetation, materials, water, soil, visibility, and cultural resources. Air pollutants are classificd as primary or secondary based upon the how they are created. Primary pollutants are those emitted directly from a source into the atmosphere. These include carbon monoxide, nitric oxide and nitrogen dioxide, sulfur dioxide, particulate matter, and various nonmethane hydrocarbons. Secondary pollutants, 6uch as ozone, are created over time in the air mass by chemical and photochemical reactions which often involve primary pollutants. These include ozone, photochemical aerosols, and peroxyncetyl nitrates. Ambient air quality is evaluated in terms of Federal standards adopted to protect thc public health. The pollutants are often referred to as "Criteria Pollutants," since they are supported by USI3'A "criteria" documents that relate given concentrations to effects on health or welfare.

J.3.2.2 Present Compliance Status

According to data provided by the Office of Air Management, Indiana Department of Environmcntal Management, JPG lies entirely within the boundaries of Air Quality Control Region (AQCR) No. 083, which is in compliance with State and Federal Air Quality Standards for all criteria pollutants.

3-34 1.3.2.2.1 Attainment at Air Quality Monitoring Sites

Four stations are located in Jefferson County to monitor pollutant concentrations associated with the Clifty Creek coal-fired power generating station. Using JPG Base Headquarters as a rcferencc point, the monitoring sites are located as follows: (1) Wilson Avenue, North Madison (suburban, commrrcial area) 3.8 miles southeast; (2) K Road (rural, agricultural) (different from the JPC K Road) 5.2 iniles southeast; (3) Graham Road (rural, agricultural) 2.4 miles northeast; and (4) Bacon Ridgc Road (riir.il, agricultural) 5.0 miles northeast.

Measurements of total suspended particulates CTSP) and continuous SO2 are made ;it each sit(,. At Wilson Ave., analyses also are made of fine particulates (PMIO), and at Bacon Ridge Road, contiiuious measurements also are made of N02. Measurements reported to the Indiana Office of Air Manapwwnt are filed with the USEPA Aerometric Information Retrieval System (AIRS), from which the following data for the period 1984 through 1987 are summarized (AIRS 1989).

Particulate matter: The annual geometric mean of TSP measurements ranged from 29 to 44 micrograms/mete? (mcg/m3),below the primary standard of 75 mcg/m3 that was in effrct at that time. The second-highest 24hour average concentration ranged between 64 and 03 mcg/m3, except for a reading of 213 mcg/m3 at Wilson Avenue in 1984; all of these are also under the primary standard of 260 mcg/m3. The observations at Wilson Avenue in 1984 were the only ones to exceed the secondary standard of 160 mcg/m3, but since that year thc trend has been downward. and no fiuther exceedances are recorded.

Sulfur dioxide: The annual arithmetic average concentration of SO, at the four monitoring sites ranges between 29 and 37 mcg/m3, compared with the primary standard of 80 mcg/m3. With the primary 24-hour standard at 365 mcg/m3, not to be exceeded more than once per year, the highest and second-highest 24-hour averages were, respectively:

- 300 and 279 mcg/m3 at Bacon Ridge Road; - 433‘ and 313 mcg/m3 at Graham Road; - 367‘ and 270 mcg/m3 at K Road; and - 354 and 325 mcg/m3 at Wilson Ave.

The secondary 3-hour standard is 1300 mcg/m3, not to be exceeded more than once a year. The highest and second-highest >hour averages were, respectively:

- 1248 and 724 mcg/m3 at Bacon Ridge Road; - 1217 and 985 mcg/m’ at Graham Road;

3 - 35 - 797 and 735 mcg/m3 at K Road; and - 1555. and 1236 mcg/m3 at Wilson Ave.

Maximum short term averages marked by (') exceeded the corresponding limits that dc4inv the standards; but since the second highest remained under the limits, no violations occurred. All high readings listed above occurred in the year 1986, which appears to have been anonlalous in this rc-spcct.

Nitrogen dioxide: The annual arithmetic mean concentration of NO, recordcd at Ilacori Ridge Road has been on the order of 0.01 parts per million (ppm), well under the standdrd of 0.05 ppm.

1.3.2.3 Air Control Permits

JM; is not considered a major source of air pollution by the Indiana Office of Air Management. The installation does not have any complaints on record and was last inspected in May of 1984 (I:oysl, personal communication, September 1989). JPG was issued an "exempt letter", February 2.5, 1W!, for three 24,000 lbs of stream/hr., #2 fuel oil-powered boilers located in Building 103 (Joshi, pcrsoiial communication, 1989; Doss, personal communication, October 1989). In addition, JIC retains a "lctlcr of registration" for a Plibrico Model 489 multiple chambered incinerator with after burner, houscd in Building 333, just north of the airport. The incinerator was registered April 26, 1978, to burn 1,000 lbs/hr of Type 0 (municipal) waste Uoshi, personal communication, 1989; Doss, personal communication, October 1989). The incinerator is not required to have an operating permit because its throughput rate is below the cutoff limit Uoshi, personal communication, 1990). Open air burning is done under an Open Burning (State Variance) permit.

J.3.3 NOISE FACTORS

Sound is mechanical energy transmitted by pressure waves in a compressible medium such as air. Noise can be defined as unwanted sound. Sound is characterized by various parameters that include the rate of oscillation of sound waves (frequency), the speed of propagation and the pressure Itvt~lor energy content (amplitude). In particular, the sound pressure level has become the most common descriptor used to characterize the loudness of an ambient sound level. The decibel (dB) scale is usrd to quantify sound intensity. Because sound pressure can vary by over one trillion times within the range of human hearing, a logarithmic loudness scale is used to keep sound intensity numbers at a convenient and manageable level. Since the human ear is not equally sensitive to all frequencies within the entire spectrum, noise measurements are weighted more heavily within those frequencics of maximum human sensitivity in a process called "A-weighting'' written as dBA. Additionally, stidden,

3 - 36 short duration infrasonic and lower frequency noise (e.g., cannon fire) is measured on a "C-wcil:htcd" (dBC) scale and is considered more disturbing than A-weighted noise.

As mentioned above, noise intensity is based on a logarithmic scale with a 3 dBA incrcwt, in perceived loudness each time the signal strength doubles. For example, if 10 autoniobilcs travc*ling iit 60 mph produce a 55 dBA noise level at 50 feet, 20 automobiles will produce a noise lrvcl of 58 dllA for the same set of conditions. Similarly, if one explosion produces a noise level of 100 DIM, two explosions of equal intensity will produce a noise level of 103 DBA under the snnie set of ccmdititrns. It should be pointed out that an increase of 3 dBA is considered barely audible under quiet conditions. As such any noise increase less than 3 dBA is considered inaudible and therefore insignificant for the purposes of this analysis.

Time variation in noise exposure is typically expressed in terms of a steady-state energy levcl (qual to the energy content of the time varying period (called Leq), or alternatively, as a statistical description of the sound level that is exceeded over some fraction of a given observation period.

Typically, an average interior maximum noise level of 45 dBA is mandated for multiple family dwellings, and is considered a desirable noise exposure for single family dwellings as well. Since nuise attenuation within residential structures with closed windows is 20 dBA or more, an exterior noise exposure of 65 dBA day/night noise level (kin) is normally the design exterior noise exposure for new sensitive residential dwellings. The Mn scale penalizes noise created between the hours of 1O:OO pni. and 7:OO a.m. by adding 10 dBA to the measured noise value when a 24 hour logarithmic avc-rage is calculated. Because commercial or industrial uses are not occupied on a 24-hour basis or are by their very nature noisy, the same exterior noise exposure standard generally does not apply for such less noise sensitive land uses.

The information presented in this section is primarily based on an environmental noise assessment conducted by theU.S. Army Environmental Hygiene Agency in 1983 (USAEHA 1983). There reportedly have been no map? changes in JPG's mission since 1983 (Stegner, personal communication, September 1989). The major sources of noise related to JPG include impulse sounds caused by the testing of large weapons and blast detonations (90-140 dB), tracked vehicles (100-115 dB), and the use of the air-to-ground gunnery range by the Indiana Air National Guard (90-120dB)(USACE 1988). The noise associated with the mission at JPG has been quantified in association with the Army's Installation Compatible Use Noise Zone (ICUZ) program (AR 200-1, Chapter 7, "Environmental Noise Abatement").

Three noise zones (defined in Department of the Army Regulation 200-1), referred to as %oneI, %onv 11, and Zone 111 are defined below for the C-weighted day-night level (CONI .), inipulsive noisr from ,111

3 - 37 weapons other than small arms, and for the A-weighted day-night level (ADNL), continuous nois(*,such as aircraft or traffic noise.

-Zone

Zone 1 c65 dBA <62 dBC Zone I1 65-75 dBA 62-70 dBC Zone 111 >75 dBA >70 dBC

Noise sensitive land uses including housing, schools and medical facilities, are considcrd as follows: Zone I-acceptable; Zone 11-normally unacceptable and; Zone 111-unacceptable.

Noise zones for tank, artillery, mortar and gun events at JPG were generated based on thc I5NOISti computer program developed by the Army Construction Engineering Research Laboratory. Noisi /on(.I. contours were developed from an average of 24 months (1981-1982) of operational data rc.latinf; thv number of rounds fired horn each weapon at each firing plant, impact points, and the number of high explosive rounds detonated at each point (Louis, personal communication, September 1989). Approximately 113,000 rounds were fired over a two year period (Table J.3.3-1), of which approximately 20 percent were high explosive. Night-time (10:00 P.M. - 700 A.M.) firing did not occur during the 24 month period.

Baseline contours for the blast noise environment previously described are depicted in Figure J.3.3-1. The normally unacceptable noise zone for noisesensitive land uses (Zone 11) extends beyond the eastern and western JPG boundaries in the vicinity of the firing line. The Zone 111 (unacceptable) noise boundary is located along the eastern boundary of JPG.

Contours generated for the addition of 20 GATOR mines detonated per day at "Y" position, using the JPGdetonation chamber, also are depicted in Figure J.3.3-1. The detonation of these mines causes the normally unacceptable noise zone (II)to extend beyond the southern boundary of the installation. The blast noise contours associated with the testing of 120mm ordnance fired at the "500 Ccnter" position show that Zone I1 extends approximately 500 feet beyond the baseline contours (Figure J.3.3-1). Contours generated for the addition of a MOPMS mine testing project site at 8lOOE (north of firing line) indicate Zone III stays inside the installation, but Zone 11 goes 1500 feet off-post Uoshi, personal communication, 1990).

The Indiana Air National Guard (INANG) uses the northwest comer of JPC for bombing and strafing practice. Noise zones for these operations were generated using the NOISEMAP computer program based on flight tracks, number of each type of aircraft using each flight track an$ altitude iis

3 - 38 Table J.3.3-1. Summary of rounds fired at JPG over a 2-year period.

Weapon Number of Rounds

105 mm Howitzer and Tank Gun 38,468 155 mm Howitzer 21354 175 mm Howitzer 243 8 inch Howitzer 6,859 60 mm Mortar 8869 81 mm Mortar 17,177 4.2 inch Mortar 8577 106 mm Recoilless Rifle 460 40 mm Gun 4,138 90mmGl.lIl 1,225 66 mm Rocket 67 3.5 inch Rocket 4,436 152 mm Tank Gun 675 165 mm Cannon 944

Source: USAEHA 1983

TableJ.3.3-2. Summary of lndiana Air National Guard aircraft operations at JPG. Number of Operations Altitude in Feet Aircraft 100-500 2000-4oM) 4000-7000 7ooO-10,000

A-7 1607 6428 4018 4018

A-10 508 2030 2537

F-4 705 2819 1762 1762

Source: USAEHA 1983

3 - 39 Blast operations

120 mm IN-ANC ordinance at oprra tions "500 center" position '1

Roman numerals indicate zones

Figure J.3.3-1. Mission related noise contours generated for the Jr'G

3-40 summarized in Table 1.3.3-2. Baseline contours for the INANC operations show that noise Zonvs II 'ind 111 extend beyond the northwest comer of the JPG property. Zone 111 extends approximately SO0 lert beyond the northwest boundary.

JPGcurrently maintains Memorandums of Understanding with surrounding Jefferson Coirn~yand Jennings County, and is in the process of obtaining the same for Ripley County. These Memor,inthims of Understanding coordinate off-post and on-post land use planning to prevent incompa~iblruws in areas of potential high exposure areas. Due to a local complaint, noise deflector barriers wcrc inst,iIld to reduce noise from the tank range at firing position A (Stegner and Luz, personal con~munic.ilioi1s. September 1989) and at firing position B (Joshi, personal communication, 1990). JPG does attcinpt to restrict the more noise intensive tests to the center of the installation.

J.3.4 HUMAN ENVIRONMENT

This section describes the human environment in terms of the aesthetic resources, archrolqyal, cultural and historical resources, and zoning and planning. Socioeconomic characteristics arc dcv ribcd and solid waste disposal is addressed as well as existing recreational resources. Hazardous rn,it~~inls and wastes known to occur at JPC are also described.

1.3.4.1 Visual and Aesthetic Qualities

This section is based on observations made during a brief site visit (August 3 and 4, 1989), aerial photography and local interviews. The entire installation could not be viewed due to ordnance testing.

Unlike JPG,much of the surrounding three county area's natural vegetative cover has been removed primarily for agricultural and development purposes. The area within the immediate vicinity of Jlr: also is primarily rural-agricultural, interspersed with small settlements, farms and single-family homes. A diverse natural resource complex is located within the boundaries of JPG because it is self-contained and geographically segregated. The view from the perimeter is forested; and the majority of internal roadsides, excluding housing, institutional areas and impact zones, are forested.

The largest area of continuous forest cover within JPG (approximately 10,023 acres) is found 111 the northern sector of JPG, north of K-Road, and inclusive of Old Timbers Lake (USACE 1986). 71'his nrca is characterized by moderate to steep ravines, exposed limestone outcrops along various valley walls, and numerous streams and wetlands. The north end reportedly has similar characteristics of Clifty Falls State Park, located southwest of the Proving Grounds, and west of the nearby City of Madison. Forested areas managed for aesthetic purposes include the stands surrounding Old Timbers Lakc%and Lodge, and some roadside forested areas (USACE 1986). .

3 - 41 Other areas of visual significance are apparent forested wetland complexes located in tlic southwestern (between Marble Creek and Fork Creek) and Southeastern (north of tlic firing line ~nd southeast of Big Creek) corners of JPG. Areas of natural interest include a Bald Cypress stand loc~.,itc. in the east central area of the testing range just south of H-Road, and a great blur heron rookrry comprised of an estimated 150 nesting pairs, located just south of K Road on Graham Creek, east of Old Timbers Lodge. Points of historical interest includeold Timbers Lodge, Oakdale School, and the douhlr and triple arched bridges (Figure 1.3.4-1).

1.3.4.2 Native American Values

No documented evidence of JPG having religious, mythological, social or other spcrial impcirl,inccB to any Native American groups has been found.

1.3.4.3 ArcheologicaVCulhuaYHistorical Resources

The purpose of this section is to report any aboriginal and historic Euro-American sites identified on the JPG, and to provide the location, type and status of these resources. Since there have been limited cultural resource assessments within the confines of the installation, background infomiation on surrounding areas is provided in Appendix I (Cultural Overview). This information will provide an indication of potential resources which have not yet been identified.

In order to accomplish the historic property requirements of the Base Realignment and Closurc Implementation plan for the Army, it is necessary to meet requirements of the NtII’A of 1966, as amended. The NHPA requirements shall be met in coordination with NEPA actions. Base realignnwnt and closure undertakings that may have an effect on significant historic places (buildings, strurtirres, sites, districts, and objects that meet the criteria of the National Register of Historic Places) must be reviewed with the Indiana State Historic Preservation Office (SHPO)and with the Advisory Council on Historic Preservation, in accordance with the Council‘s regulations (36 CFR 800). Coordination for a planned cultural resources survey is currently on-going between the Indiana State Historic Preservation Office and JPG staff. The survey, planned because ofJPG’son-going timber program, will be condiickd north of the Firing Range where the timbering will occur.

A literature review was conducted of potential or known resources on the installation. The Indiana State Historic Preservation Office was visited September 6,1989, and State site files, archives, and other requisite documents and sources were made available by the SHPO staff. Archival data also were reviewed at the Indiana Division of the Indiana State Library in Indianapolis, Indiana. Vcrhal consultation with Dr. James Cooper (1989) of DePauw University, in Crerncastle lndiiinii, was iii8idc*

3 - 42 H 0 mi. 1 mi

LEGEND

Hcadquarters

117 Bridge and Number s Oakdale School

Old Timbers Lodge

1975 Archeological survey

Monuments of route Morgan’s raiders took during the Civil War

BRIDGE INFORMATION

NO.17 Three spans, each arch spanning 50.60 feet.

No. 25: Shortest and only singlr- span bridge of the four; scgmcntal arch.

NO.27 Three spans with wide arches from 42 to 48 Iect.

No. 28 The only two-span of the four bridges.

Figure J.3.4-1. Historic cultural resources identified within JIG

? - 41 concerning the extant bridges located within JPG. The results of the literature review are reportd iis follows.

J.3.4.3.1 Prehistoric Cultural Resources

One prehistoric archeological site has been reported within the boundaries of the JPC. In 1975, Guendling, of the Glenn A. Black Laboratory in Bloomington, conducted a I'liasc 1 siirvry within tlic Proving Ground, in Ripley County. He tested 150 acres north of Graham Creek for the pro1ioscd location of a gunnery range (Figure 1.3.4-1). One fragmentary projectile point diagnoslir of tli(, Iiik Woodland/Mississippian time period was found on the upland flat north of Graham Crcxk No otlier materials were found in the vicinity of the point or within the 150 acres. However, surface visihility iind ground disturbance greatly inhibited reconnaissance of the area (Guendling 1975; Stafford et '11. IW5).

No other archeological surveys or projects have been conducted in JPG to search for prehistoric cultural remains. A review of the known archeological sites in other parts of the counties ronhining the installation is included in Appendix I.

1.3.4.3.2 Historic Cultural Resources of JPG

No organized surveys or projects have been conducted in the JPG to search for existing historic structures. A compilation of possible historic sites within the boundaries of the JPG has been completr by Stafford et al. (1985). These possible historic sites were identified from historical atlases, plat books, and other maps published between 1876 and 1921 and includes potential historic sites from Jeffvrson, Ripley and Jennings counties. Information concerning the surrounding Jefferson, Ripley and Jennings counties are included in Appendix I.

The potential significance of several of these historic sites has been recognized in previous reports and research. The Oakdale Schoolhouse, built in the 1860s. exists in Section 28, Monroe Township, Jefferson County, within the Proving Ground boundaries (Figure J.3.4-1). It is one of the few remaining one-room schoolhouses in the local area (Building Technology Inc. 1984). The building was constriictcd of limestone masonry circa 1870, and is a good example of an intact architectural type. The schoolhouse was reported in fair but deteriorating condition in 1984 (Building Technology Inc. 1984) and is also out of the line of fire of any of the testing areas. The Indiana SHPO nominated that the Oakdale School was eligible for listing on the National Register of Historic Places in January of 1986. The lndiana SlHl'O found that the building had retained much of its original integrity, and exists as one of the few remaining one room schoolhouses in Jefferson County (Indiana SHPO 1986). JI'C is currently aw,iiting an lndiana SHPO decision.

3 - 44 The Jefferson County Historical Society has established three monuments on JK,drpicting 11w route of John Hunt Morgan's Raiders during the Civil War. The supposed route crossed from 1)uI'ont cross the Proving Ground to the original Michigan Road and then up to Versailles, Indiana. 'l'his roiik most likely duplicated what is now called D Road (Figure 1.3.4-1). The three nionumcnts arc:

1. Intersection of Morgan and D Road 2. 100 yards west of where Center Recovery Road joins D Road. This site marks the capture ol three of Morgan's men. 3. Just south of the D Road-Cottrell Road intersection. This site marks the original road.

The Old Timbers Lodge, located in Section 34, Otter CreekTownship, Ripley County, also was found to be a potentially significant structure still intact within the boundaries of the fncility (1;if;im J.3.4-I ). This structure was built as a country house in the 1930s by Cincinnati industrialist Alexander 'l'hoiiisr~n. The installation uses the structure at present as a recreational lodge and facility for staff pcrsonnd. It was built in the arts and crab tradition of the early 20th century and features a "Great Hall" flnrikcd by massive stone fireplaces. Its significance lies in its importance as a local landmark, and is ii good example of an early 20th century country house (Building Technology Inc. 1984). It was found to be a Category III structure, designating minor significance. The Indiana SHFO agreed with that asscssmcnt and determined, in January 1986, that the Old Timbers Lodge was not eligible for inclusion in the National Register of Historic Places (Indiana SHPO 1986).

Four stone arch bridges also are known to exist within the Proving Ground boundaries (I"{,.I wre 1.3.4-1). One of these (Bridge 300091, JPG Bridge No. 17, is listed as a Historic Inventory site by the Historic Landmark Foundation of Indiana (1989) and is estimated to have been constructed in 1895. 'l'he other three stone bridges are of similar construction. They exist as excellent examples of local masonry bridge design and construction. In response to a request by the U.S Department of the Army to determine the eligibility of these four bridges, the Indiana SHPO asked James L. Cooper Ph.1). of DePauw University to evaluate them and to determine their significance. This process was documtrntcd in a series of letters between the Indiana State Historic Preservation Office (1985; 1986; 1YX7; 198%: 1989b; 1989c), the U.S.Department of the Army (1985a; 1985b; 1988; 1989), Michael Baker Jr. Inc. (19)87), and Dr.James L. Cooper (1989). As part of a statewide survey of historic bridges in Indiana, Dr. Cooper evaluated the status of the four stone arch bridges located within the confines of JPC. Using information and photographs provided by the US. Department of the Army in a letter dated 1988, Cooper provided an assessment and description of each of the bridges in writing in March, 1989 (US. Department of the Army 1988; Cooper, personal communication, 1989). The Indiana SHPO deterinincd in April, 1989 that all four bridges (Bridge Nos. 17,25,27,28) were eligible for inclusion in the Natic~ri~l Register of Historic Places (Indiana SHPO 1989~).

3 - 45 Some of the other bridges found within the boundaries of the JPG may also he potcntinlly significant. Metal and wooden truss bridges were built in the local area in the laic 19th c'vntilr. (Cooper, personal communication, 1989). These are, however, rapidly being replarcd by ri-iiiforri concrete bridges. These metal bridges are direct descendants of the wooden prototype devc4optrl in the 16th century by the Renaissance architect Andrea Palladio. Increasing induslrializalicin in ltw 19th century, and the use of pre-fabrication, made the development of these bridges possible. 'l'hrir ~x~~v11Iii11 significance results from their survival as good examples of an intact historic engineering type. Sonic of the local bridges werealso cast by regional companies such as the Lafayette Bridge Conipnny (Corinty Bridge No. 64,Jennings County). In his letter of 18 March, 1989, to the Indiana SHPO,Cooper indicalcd that it would also be useful to inventoly the metal and concrete spans standing within thr ]IT (Cooper, personal communication, 1989)

J.3.4.3.3 Archeological Site Potential

The objective of this section is to correlate known archeological and historic site locations within and around JPG to assess the potential for the occurrence of such sites within the bwndaries of the Proving Ground. The prediction of culturally sensitive areas is derived from information gathered on rcgional site patterns as well as an evaluation of the model through field testing. Based on information fFiiiied from cultural and environmental background research, as well as a review of previous field studi(*s in the region, certain parameters governing the suitability of different environmental settings for site locations have been recognized. These served as guidelines for determining site potential williin tb. project area.

Parameters such as distance to water, visibility, and topography played important roles in prehistoric and historic site locational choices. In general, the most probable locations for prehistoric and historic sites are the floodplains of major drainages, terraces, and slope benches above streams, areas on and near the height-of-land, ridgetops near spring-fed headwaters, caves and rockshelters, and areas near long-established roads.

Prehistoric

The topography of JPG is conducive to prehistoric activity, an observation discussed in the findings of other mltural resource reports undertaken in south and central Indiana. Major projects such as a natural gas pipeline survey of over 100 miles through south-central Indiana (WAPORA 1987a and 1988), and other smaller projects such as the Webb Borrow Pit study in Ripley County (Cree 1989) illustrate the presence of large numbers of prehistoric sites across south-central Indiana.

3 - 46 Archeological investigations along a Texas Gas Pipeline where it crossed the Camp Allcrbury Reserve Forces Area in Bartholomew County, found that archeological sites can survive siirfacr disruption. Camp Atterbury is a National Guard training ground that, like Jl'G, uses live ordnance. A total of 25 sites were located within the Reserve (WAPORA 1987). Eleven of these contained rnough intact materials to be considered potentially significant. The discovery of this many sites along a iiiirrow 14.3 mile corridor indicates the potential for archeological sites to still exist within JIG

One prehistoric archeological site was located within JPG, during a survey of 150 acrcs (Ciiviiciling 1975). The prehistoric presence that this represents in the region, however, is reinforced by Ihr prcwnw of almost 400 recorded archeological sites in the surrounding three counties. jcfferson <:oirnty has h;rd over 190 sites recorded, and over 100 sites have been recorded in Jennings and llipley Counks. 'l'l~e majority of these sites were found within 500 meters of a visible water source such as a slrcam or qwiiig and on slopes or crests of upland flats overlooking the water sources. Proximity to water, well-driiincd soil, and visibility played important roles in prehistoric site selection.

The topography of JPG, in addition to the presence of large numbers of local archeological sitrs on similar topographic settings, indicate a high probability that many prehistoric archeological sit<-sare located within the Proving Ground boundaries. Upland flats and gentle slopes along the five strc.ams and their tributaries, as well as the minor floodplain areas of Otter Creek and Rig Creek, ,ire typical locations for prehistoric resources. With accompanying tributaries, fresh water is accessible from virtually any given location in the Proving Ground. This proximity to a water source makes lnrgr portions of the Jl'G culturally sensitive areas.

Historic

The long history of the three surrounding counties is evidenced by the settlement of the area in the early years of the 19th century. According to Historic Landmark Foundation reports for Jennings and Ripley counties (1986; 1989b) many historic structures and farmsteads have survived into the present. The rural nature of much of that century has also helped preserve the counties' historic nature. Except for the establishment of the Proving Ground in 1941, little expansion or development has taken place in the surrounding counties. The City of Madison, located in Jefferson County, has had sonie recivil development, yet the historic nature of much of the local area has been recognized. The Madison Historic District was listed in the National Register of Historic Places. The known existence of significant historic sites such as the Oakdale School and the four stone arch bridges indicate the probability that other significant sites and structures still exist within the Proving Ground.

Some potential historic sites were leveled in the early 1940s during construction of JPC (Kiki-r 1952). The use of the facility for live ammunition testing has also impxted largv portions .of tlw h.i\ity.

3 - 47 Present impacted areas and depth of disturbance are illustrated in Figure 1.3.4-2. Other Impnclrii arws (and depth of disturbance) that were used in the past, for which records were not kept, are not shown in Figure 1.3.4-2. However, the unrecorded impact areas are located almost everywhere north of tlic firing line Uoshi, personal communication, 1990). Old Timbers Lake has also been crealed in the northern portion of the facility, and has inundated a portion of Little Otter Fork. Although portions of the facility havebeen heavily impacted, large areas of undetermined status lie among thiw arcw wiUiiii the Proving Ground boundaries.

J.3.4.4 Zoning and Political Boundaries

Planning and Zoning

The majority of the planning and zoning effort in the three county JPG region takes placc ;it the county level. Jefferson County has adopted both a comprehensive master plan and a zoning ordiniinct.. The master plan was prepared in 1973 with no major revisions or updates made since then. Tliv plan is not a major mechanism for future land use planning. The zoning ordinance was adopted in 1974 and has been updated periodically to reflect changing conditions and needs. The last major revisions occurred in April, 1986. The ordinance has jurisdiction over the entire County, except where individual municipalities have adopted their own ordinances (e.g., the City of Madison and the Town of Idanover).

The City of Madison is the most significant urbanized area in the region (est. 1989 populalion: 11,617, Editor and Publisher). The City adopted a comprehensive plan and zoning ordinance in 1981. The plan is currently utilized in conjunction with the zoning ordinance to foster the ordrrly and controlled growth of Madison.

Jennings County adopted a comprehensive plan and zoning ordinance in 1973. The plan is out of date and there are no plans underway to revise it. The zoning ordinance currently acts as the County's land use control mechanism and has been periodically revised to reflect current conditions. The zoning ordinance covers the entire County with the exception of the City of North Vernon, which adopted its comprehensive plan and zoning ordinance in 1969.

Ripley County adopted its comprehensive plan and zoning ordinance in 1970. The plan has not been followed for years and the zoning ordinance is in the process of a significant revision. The zoning ordinance covers the entire County, except for the City of Batesville and the Town of Osgood which have adopted individual ordinances.

3 - 48 +iL MAPPING CODES

PERCENT OF TOTAL AREA DEPTH OF GDA No DISTURBED DISTURBANCE 1-39 > 90 > 6h 40 > 90 0-3h 41 60-90 0-3h - 42 < 30 0-3h

I (Source: Riker 1952)

-- -- Figure J.3.4-2.- Map of historic and/or modern ground disturbance -- that might limit the archeological resources based on the JPC.

3 - 49 There are no special use designations either on, or contiguous to, the installation in any 01 IIic counties. The majority of land contiguous to JPG is zoned as "Agriculture" by a11 i~pplicahl~~zoninl: ordinances (Figure J,3.4-3). The Louisville District Corps of Engineers Real Estate Ilivision (Appriiisi, Branch) recently conducted an inquiry of the three county zoning ordinances. 'l'lw Appraisal Ilr4iiich reported that the portion of JPG located within Ripley county is zoned Agriculluri,-l and 11ic nrcii adjacent to JPG is zoned Agriculture-2. In addition, the portions of JPG located withiti Jdfi*rsoii and Jennings Counties are zoned Agriculture. The A-1 designation specified that the land is highly siiiliililr for agricultural use, whereas A-2 is adequate but less suitable than A-1. A small portion ol tliv land along the southwest boundary of JPG in Jefferson County is zoned as R1 Residrntial (I;igurc J.3.4-3). An R1 designation permits single family dwellings on a minimum lot size of 10,000 siyiarv IWL.

The existing community land use plans or controls currently in effect do not restrict or inhibit tlic ability of JPG to carry out its designated testing mission. Environmental noise impacts, rcsultiiiy, from ordnance testing and flight training exercises by the INANG, have the potential to be the soiircc of larid use incompatibility between JPG and the community. JPGhas developed and issued recomnirn[i;itior~s to abutting municipalities regarding community land use policies. The recommendations hiIw Iwcm issued as part of the JPG Incompatible Use Zone Analysis (ICUZ). The recommendations primirily stress the need to keep areas in close proximity to installation boundaries free from devchpmciit that may be incompatible with JPG's test mission. The aim is to protect the community from potcmtiiilly adverse effects of excessive and unwanted noise generation.

Floodplains

There are no officially designated floodplain management areas either on or in close proximity to JPG. According to the Federal Emergency Management Agency (FEMA), no official hydrologic analysis has been conducted for J"G or nearby surrounding areas regarding floodplain delineation and flood hazard boundary designations. JPG is located on an upland plain and is not prone to severe flood potential.

Easements

There are currently no outside easements or rights-of-way crossing the installation. JI'C holds a utility easement for an abandoned 31,500 foot eight-inch water main. The easemenl extends south from 1% Gate 22 through Jefferson County and the City of Madison to a pump station along the Ohio River. JPG previously obtained its own water from aquifers along the Ohio River. In November, 1985 JI'G began purchasing water from the City of Madison. As a result of the changeover, JT'G ahandonrd Ihc old supply line, yet maintains the easement.

3 - 50 AORICULTURE P

AORICULTURE

JEFFERSON Go.

BRYANTSBURG

NROE TOWNSHIP

--- CHINA ------AORICULTURE

I SMYRNA TOWNSHIP MADISON CITY

LEGEND --- COUNTY LINE --- TOWNSHIP LINE

Figure J.3.4-3. Community land use within the JFG.

3 - 51 1.3.4.5 Socioeconomic Characteristics

This baseline profileof existing socioeconomicconditionsconsiderscharacteristics relevant tom-post JPG conditions and the designated surrounding region. This profile describes existing sociocmmomic conditions and the relationship of the installation to its surrounding region. It also identifie potential constraints or areas of concern which could require further consideration during closure and realignment.

The Institute for Water Resources (IWR) was tasked by the Army Base Realignment and Closure Office (BRACO) to conduct analyses of socioeconomic impacts in the subject areas of population, regional economic activity, housing, and schools of all Army BRACO actons. As part of IWil's I'liasc I1 Socioeconomic Effects Analysis for JPG UPG SEA Report, IWR 1989), the regional impict area dcfincd by IWR for JPG consists of Jefferson, Jennings, and Ripley Counties. The affected socioeconomic environment of the three county area is described in this section.

J.3.4.5.1 Installation Overview

JPG was established in 1941 as a Class11 military installation assigned to the Ordnance Department, Army Services Forces, with the mission of production acceptance and specification testing of all types of ordnance. Established just prior to World War 11, JPG's mission levels and proof acceptance production have been marked with cycles of intense activity followed by long periods of idleness and' at times, deactivation.

JPG's peak periods of production occurred during the times of recent national conflict (World War 11, the Korean War and the Vietnam War) with maximum production (175,000 rounds/month) and employment (1,774 employees) reached in 1953. After each conflict, periods of idleness would occur due to the lack of need for large-scale proof test requirements. After World War II it became a subpost to the Indiana Arsenal and was placed on standby status. From 1958 - 1961 JPGwas again on standby status and partially deactivated, with some facilities leased to civilian private sector uses. In the 1970's a gradual decline in production and employment occurred. Most recently, the increased emphasis on national defense, readiness capability, and conventional warfare in the 1980s brought about modest increases and diversification in production acceptance testing. Prior to the notification of closure, JPG was in the process of increasing its productivity by 25 percent and planning to modernize its facilities based on recent directives from TECOM, its Major Command. The increase in overall workload and testing capability would be accomplished without a corresponding increase in workforce positions, but through efficiency and new technology.

3 - 52 1.3.4.5.2 Population

The total authorized personnel at JPG was 421 as of July, 1989 (IWR SEA Report). Of thrse personnel, 14 were military and 407 were civilian. In addition, there are approximately 33 mililary dependents and 791 civilian dependents. It has been determined by IWR that all military persoriricl and their dependents reside on-post for a total of 47 on-post residents. All civilian personnel arid thrir dependents reside off-post.

The 1980 regional population was 77,671 (IWR). The estimated regional population for 1989 was 78,011, an increase of 0.4 percent. The projected 1994 population is 78,582, an increase of 0.7 pc*rcrnt (Table J.3.4-1).

Between 1969 and 1979 the region experienced steady to rapid growth, which began to taper off during the early 1980s. A net decrease of lo00 people was experienced by the region between 1984 and 1986 with rebound occurring during 1986-87. Prior to the announced closure of JPG, slow popillation growth was projected through 1994.

The number of households in the region grew from 19,748 in 1970 to 25,802 in 1980, an increase of 30.7 percent. Little, if any, of this increase was attributed to significant personnel increases at JI'C. In fact, the 1970s was a period of personnel decline; JPG had an installation strength level of 956 employecs in 1968. By 1978 the JPG workforce had been cut back to 368 civilian employees. The 1989 estimate is 27,806 households, an increase of 7.8 percent (IWR). Projections for 1994 indicate a much slower household growth rate. In 1994 an expected 29,060 households will be in the region, an increase of 4.5 percent (Table 1.3.4-1).

J.3.4.5.3 Land Use

--On-Post

The land currently comprising JPG property was primarily used for agriculture prior to purchnsc. JPG consists of 55,268.30 acres of land, of which 55,264.17 acres are held in fee simple title and 4.10 ,ic'rc~s are held in easement. Less than 3 percent (1,591 acres) of the land area consists of improved land.

Existing land uses at JPC have not changed significantly since the Proving Cround was first established. Land uses on the Proving Ground are identified on Table 1.3.4-2 and Figure J.3.4-4and Figure 1.3.4-5. The acreage north of the main firing line is primarily devoted to operations testing whereas the area south of the main firing linecontains the cantonment area, with operations, operational support and administrative functions. .

3 - 53 Table J.3.4-1. Selected socioeconomic information for the JPG Region

Reeional Population

1989 1994 Defined IPG Region --1980 1987 (Estimated) (Proiected) jefferson, Ripley and Jennings Counties 77,800 77,700 78,011 78,582

Reeional Households

1989 1994 Defined IPG Reeion --1980 1987 JEstimated) lProiected) Jefferson, Ripley and Jennings Counties 19,748 25,802 27~1806 29,060

Year-Round Housine Units, IPG Region

Total Occupied Vacant Persons

Total 27,902 25,802 2,100 74,561

Owned 20,672 20,321 351 60,781

Rented 6,055 5,481 574 13,780

Other 1,175 0 1,175 0

Source: IWR, Phase II SEA Rewrt. IPG. 1989

3 - 54 Table 1.3.4-2. Existing land use - JPG.

Percent of Fee Simple Land Use Function Acreage Ownership

Operations/Operational Support' 53,436 96.69

Industrial2 (1,034)

Safety Zone) (10,490)

Test Range (41,912)

Training' 1,557 2.81

Supply /Storage I33 0.24

Recreation 61 0.11

Family Housing 60 0.11

Administration/

Community Facilities 14 0.03

Medical 3 0.01

SUBTOTAL 55,264 100.00

Easement 4

TOTAL 55,268 NOTES: For purposes of conelating existing land use acreages with the 1980 Analvsis of Existing Facilities/Environmental Assessment Rewrt, this table groups land use function within categoric+ a8 follows:

1. Operations and operational support land uses include industrial land uses, the safety zone, and the test range.

2. Industrial land uses include maintenance and utilities land uses.

3. The safety zone includes forest management areas, marshlands, and wildlife reserve areas.

4. Training land uses include 557 acres in the southern part of the Proving Ground and 1000 acres north of K Road used by the Indiana Air National Guard. .

Source: USACE 1988

3 - 55 SAFETY ZONE

OLD TIMBERS LAKE INMANA AR NATIONAL GUARD FLWT PATN

OLD TIMBERS LOOOE

LAND USE CL.ASSIFICATIONS OPS Operations REC Recreallon TRG Training

SCALE I( FEET

SEE FIGURE J.3.4-5 F

TWz CANTONYENT AREA

Figure 1.3.4-4. Existing land use within the JPG.

3 - 56 LAN0 USE CLASIFICATIONS AOM Admlni*lr.lion

CF Connnunilv F.slllii.. FH Family Hou-ing M Mmdlsal MNT Walnl.n.nce OF% Op.r.tlon. OPSU Op.1.ilon.l S"pp0,l REC Rscre.llon s/s Supply/Slor.g. TUG Trdning UT Ulllll..

0 1m 3200

fj KEY MAP

Figure J.3.4-5. Existing land use within the JPC. Operational land uses are defined as activities which support the installation's primary mission Operational land uses at JPG include: industrial, including maintenance and utilities; the salrly milt encompassing forest management areas, wetlands and wildlife reserve areas; and the tcstin); arm Operational uses occupy over 97 percent of all land uses on the installation.

Family housing areas consist of thirteen units located in the cantonment area around Offiwrs Quarters Road. JPG military personnel and their dependents occupy three units; all othcr units iirr occupied with military tenants. The units, relocated to the site in 1941, are in gciwrally good rtrntlilion. Also included in the family housing area are fourteen detached storage buildings and ten dc.t;ichid garages. Other uses of JPG land occur under strictly controlled conditions, including timber hnrw~slinl; (15,000 acres), recreational hunting (35,000 acres), fishing and camping.

Adjacent Communitv Land Use

JPGis located within several subcounty municipalities (Figure J.3.4-4). The three county area iiround JPG consists of 1,185 square miles or 758,400 acres. The land is principally rural with the vast majority characterized as either agricultural or woodland.

Major land uses within the JPG region are detailed in Table 1.3.4-3. Communities in the rcb'.wm are widely distributed with very sparse strip residential and agricultural development interspersed .ilnn~' existing highway networks. The population density for the three county region in 1980 was 61, persons/square mile; in contrast, the density for Indiana was 155 persons/square mile. Thc City of Madison is the most highly developed area in the region; it had an estimated 1988 population of 11,617 (Editor and Publisher).

Land immediately adjacent to JPG consists primarily of agricultural uses and woodlands with very sparse residential development along U.S. Route 421, U.S. Route 50, and Indiana Route 7. The nearest communities to JPG are very small and unincorporated. The Madison Central Business District is located approximately eight miles south of the JM; Main Gate (Gate #I).

There is very little relationship in terms of land utilization between JPG and the surrounding rcb'1 'ion. The potentially dangerous and hazardous nature of JPG's operational mission dictates that the installation remain operationally segregated from the community. The installation is fenced around its approximate 50 mile perimeter to prevent public access and provide for public safety and welfare.

3 - 58 Table 1.3.4-3. County land uses in the JPG vicinity.

Percentage of Total Square Urban/ Counties -Miles -Acres Built-up Amicultural Forest IpG Water

Jefferson 366 234,240 4 61 25 9 1 Ripley 442 282,880 4 65 20 10 1 Jennings 377 241,280 3 76 16 4 1

-NOTE: Acreage utilized by JF’G in each County are as follows: Jefferson-19,805 acres Ripley -27,084 acres Jennings- 8,375 acres

... SOURCE: Southeastern Indiana Regional Planning Commission, 1986. US. Department of Agriculture, Soil Conservation Service, Jefferson County (1985), Ripley County (1985), Jennings County (1976).

3 - 59 J.3.4.5.4 Regional Economic Activity

Regional overall economic activity has been improving in recent years as rcflcytrd hy ri~};ional unemployment figures as gathered by IWR. The annual average (AAV) unemployment rak [or the region has decreased from 6.64 percent in 1987 to 5.60 percent in 1988. As of March, 1989. it stood at 5.36 percent. During this period the civilian labor force has also grown slightly (1987 AAV = 35,823; 1988: AAV = 37,538; and March 1989 = 37,687), which reflects slow steady increase in rq;ional employment and economic activity. The role of JPG in the gradual improvcmcnl ol llii> rqional economy has been minimal. The JPG civilian workforce has changed only slightly during thc IOHos. From 1980-1990, JPGs civilian workforce increased from 394 to 407, an increase of 3.3 percent. It was not expected to increase in significant tern in the future, according to recent JPC modernization plans.

An analysis of the average annual data for all employment sectors indicates that the 1988 civilian labor force was 37,538. Manufacturing was the largest employer in 1989 at 25.6 percent of the total labor force. It is estimated that 1.2 percent of the total civilian employed labor force in the region work at JPG.The 1989 regional per capita income was $9,839. The 1994 regional per capita income is projrckcl to be $11,874. The regional total personnel income was $872.3 million in 1987. In contrast, thr .innual average wage/salary per JPC employee (i.e. 407 civilians and 3 military) was $29,268, as Jeterminid by IWR figures.

1.3.4.5.5 Housing

The 1980 census shows a regional total of 27,902 housing units of which 25,802 are occupied, resulting in a 7.5 percent vacancy rate (Table J.3.4-1). There are 407 civilians with 791 dependents living off-post. These off-post civilians pay, on average, $157 per month for rental units or own homes with an average value of $32,931.

J.3.4.5.6 Schools

JT'G maintains no Department of Defense Dependent Schools on-post. According to data providtbd by JI'G to IWR, there are a total of 314 dependents of JPG employees attending public schools in 22 school districts located throughout southeast Indiana and northern Kentucky (Phase I1 SEA Report, JlC Socioeconomic Datacall, September 1989). Eighty percent of these students are enrolled in the following school districts:

141 - Madison Consolidated (JFGRegion) 46 - Southwestern Consolidated (JPC Region)

3-60 37 - South Ripley County UPG Region) 18 - Trimble County, Kentucky (non-JPG Region) 12 - Switzerland County (non-JPG Region)

The remaining 20 percent (60students) attend schools in 17 other school districts located bo111 wilhiri and outside of the designated JPG region. There are also 17 JM; dependents cwrollrd in privatv elementary and secondary schools, 31 in two vocation schools, and 64 in collegcs and rinivcmitic%s.

No schools in the ]I% region receive PL-864 Federal Entitlement Aid Assistance, according lo JI’C; information provided to IWR (JPG Socioeconomic Datacall).

J.3.4.5.7 Health Care

Health care facilities for personnel at JPPC consist of the Occupational Health Nursing Office (OHNO). OHNO operates as a tenant activity under the command of the U.S. Army Health Srrvices Command Medical Department Activity (MEDDAC), Fort Knox, Kentucky. OHNO provides only minor out-patient or emergency medical care to on-post JPPC personnel, including dependents, rctircd mililary personnel, and DOD authorized personnel. OHNO provides on-post ambulance service for use during testing operations and on-post emergencies. The office has only minor medical care and diagnostic capabilities; no laboratory or X-ray facilities are available at the clinic.

More sophisticated or advanced treatment requires surface or air transport to either local or regional health centers in the area, depending upon severity of the problem. The most convenient local off-post medical facilities in the region are Madison State Hospital and King’s Daughter‘s Hospital, located in Madison. Other off-post regional health care facilities offering medical services include:

- Jennings Community Hospital, North Vernon, Jennings County - Margaret Mary Community Hospital, Batesville, Ripley County - Jackson County Schenk Memorial Hospital, Seymour - Clark County Memorial Hospital, Jeffersonville, Clark County

J.3.4.5.8 Public Safety

Public safety at JPG falls into two basic areas: safety operations and restrictions dirlrlly relaled to the ordnance testing mission; and service-type safety functions that act in support of the JI’G testing mission.

3 - 61 The nature of JPC's ordnance testing mission dictates that operational safety he an iinport;inl element of mission testing policy. Safety functions and operations directly related to Ilw JIY; I~~slin, mission are administered by the Safety Office.

During testing operations, two land use restrictions are used to provide off-post and on-post safoty. JPC maintains a 1,200 foot continuous safety zone comprised of 10,490 acres adjacent to thc prriineter of the test range north of the main firing line in which all operational activities are prohil>itcul.Ow post, officially designated safety fans must be used for each individual impact zonc or test iirw within the test range. South of the main firing line, quantity distance safety arcs, as defincul iir (lit. AMC-R 3x5-100 are utilized for individual testing areas and storage areas/facilities utilizing explosive or pot(mti;illy harmful material.

Safety carried out in support of the JPG test mission consists of service-orienttd functions in the form of law enforcement and security, fire protection, emergency medical services, and hazardous material response teams. The Directorate of Law Enforcement and Security (DLES) provides frir and administers programs regarding to intelligence, preservation of order, and related security at JN;.The DLES maintains 25 guards and 3 overhead personnel. Five vehicles are utilized 24 hours/day in carrying out DLES functions. Patrols of facilities and the installation perimeter are the primary duties of the DLES. No off-post law enforcement services are utilized as part of JPc's mission support functions; all law enforcement and security functions are carried out in-house.

Fire protection/prevention, emergency medical services, and hazardous material spill response services carried out in support of the test mission are administered within the Fire Protection IXvision of the Directorate of Engineering and Housing (DEH). As with law enforcement, all such services are carried out completely in-house. The Fire Protection Division is located at the on-post fire station in D- 125. A total of 13 full-time personnel are currently on staff operating in two 12- hour shifts. 1\11 staff members have the required training to respond to emergency spills on an as- needed basis.

Fire protection facilities consist of a soO,OOO gallon on-post water tank reserved solely for fire protection purposes. Water for site-spedfic fire suppression is accessed through a system ol 89 fire hydrants throughout the cantonment area.

JPG interacts with off-post local emergency service providers through several mutual aid agreements. JPC also maintains mutual aid agreements with the law enforcement agencies in the City of Madison, surrounding municipalities, and the Indiana State Police for use of the installation's auto extrication equipment.

3 - 62 J.3.4.5.9 Traffic and Transportation

The on-post transportation system at JPC consists of a road and bridge network, railrnad fii(4itic-s, and an airfield (Figure J.3.4-6). There are 174 miles of improved roads at JPC; 24 miles arc concr(~tvor asphalt-based and the remaining 150 miles are gravel surface. The primary and secondary roads in tlw cantonment area are paved. West Perimeter Road, East Perimeter Road and a section of K-Road,cwt of MachineGun Range Road, are the only paved roads in the test range area. The remaining roads arc primarily gravel surface, with a few classified as unimproved dirt. Most of JPCs primary mid secondary roadways, both north and south of the firing line, are in good condition.

As part of the roadway system, JPC maintains a system of 26 bridges and water crossings to provide access to test range impact areas and firing points. The majority of the bridges on-post arc in !;wd condition and require routine maintenance to keep them in effective operating condition.

]IC is served by three interstate/national defense highways: 1-65, traversing north/with approximately 30 miles west of JM;; 1-74, traversing east/west approximately 40 miles to the north; and 1-71, traversing north/south approximately 30 miles to the east in Kentucky. Local dirert access to JIC is provided mainly from US. Route 421, a two-lane directional roadway classified as an IJrh.in Connector on the Federal-Aid Highway System.

JPG does not experience significant traffic congestion or access problems due to the rural location of the installation. The most recent annual average daily traffic (AADT) figures from the Indiana Department of Transportation (IDOT) an AADT rate of 3,750 vehicles on U.S. Route 421 at the JPC main entrance gate (Gate #I) (IDOT 1983 figures).

JFG initially was developed with full-service railroad capabilities which served as the principal mode of transportation of ammunition and test components. JPG has 16 miles of standard track, all of which are located south of the firing line. The on-post rail system gradually fell into a state of disrepnir throughout the 1960s and 1970's; on March 30,1976 approximately ten miles of track were condeninid. Six miles of track on-post remain operable. The condition of JPC's rail system is generally vrry poor and continues to deteriorate due to lack of system need or demand. JPG now relies primarily on over- the-road trucking to accommodate shipping/receiving needs.

JFG's regional rail service was served exclusively by the Madison Municipal Railroad. Owned and operated by the City of Madison Port Authority, the rail line is a 24 mile sole source spur from Madison to North Vernon in Jennings County. The system has deteriorated badly, is poorly maintained, and is in need'of major capital improvements. Further, the Chessie System is currently implementing plans to abandon approximately 70 miles of track between Aurora to the east and Seymour to- the wcst.

3 - 63 LEGEND V AIRPORT / RAILROAO

%-*. RAILROAD TO BE ABANDONED e RIVER .- MAJORHIOHWAY MADISON RIVER TERMINAL

Figure J.3.4-6. Regional tramporation map.

3-64 The on-post airfield at JPC was constructed in 1941 and consists of the following:

Fixed runway (concrete): 316,667 square yards (SY)at a length of 5,000 feet

Standard Taxiways (concrete): 56,325 SY

Aprons: 38,797 SY

Airfield hangar (8-301): 24,084 SF

The existing airfield no longer is utilized for aircraft operations and has fallen into general disrqiiiir. Current JPGair transportation requirements are handled either through regional metropolit;i ti airports or the Madison Municipal Airport, located approximately 8 miles away.

1.3.4.5.10 Wastewater Disposal

Sewage collection and treatment is attained through the use of an on-post system manap4 and operated by JPGpersonnel. The sanitary sewer system predominantly is gravity flow except for thc low lying areas which are serviced by four lift stations. Constructed in 1941, the plant has a capacity of 270,000 gallons per day (gpd) with an average sewer flow (1986 - 1987) of approximately 60,000 gpd.

The wastewater generated at JPG is almost entirely domestic sewage. lndustrial wastewater accounts for a minimalamount of total wastewater production. Industrial wastes consist of photographic wastes, which average approximately 170 gpd, and boiler blowdown, which produces from 200 tn 300 gpd during the winter months. These amounts have remained essentially the same for the past decade and do not constitute environmental compliance or capacity utilization problems.

Excessive infiltration/inflow problems have occurred in the past from storm drainage during heavy rainfall and wet weather periods. The problems are due to the age of the existing vitrified clay pipe (VCP) lines located throughout the southern portion of the installation. Approximately 28,000 lincnr feet of heavily leaking VCP lines were replaced in 1988-89.As a result of the recent repairs, JI’C is in compliance with applicable total suspended solid (TSS) levels required by the installation’s currcnt NPDES permit (which allows 15 mg/l TSS weekly average and 10 mg/l Tss monthly average) (Joshi, personal communication, 1989; Cluxton 1989). JPG has always been in compliance with other NPDLS permit requirements (Joshi, personal communication, 1990).

3 - 65 Further, JFG has been issued a new NPDES permit effective through Aup~sl, 1995 New requirements include additional monitoring for ammonia-nitrogen, dissolvtd oxygrn, and rc--idital chlorine.

In addition to the treatment plant, septic tanks are utilized at 8-510 and 8-708 (Y-l’osition), I<- I85 (Old Timbefs Lodge), B-194 (Rad Road) and B-269. No sanitary sewer service is providrd or i~viiilalile north of the main firing line.

J.3.4.5.11 Solid Waste Disposal

jPG maintains and utilizes four active disposal sites on the installation. These sites are catep,t)rized as operational support land use areas. The solid waste disposal areas are comprised of the following sites:

A 12-acre landfill used for non-sanitary and non-hazardous waste disposal. The laiid(il1 is located in the southwestern sector of the installation adjacent to West Perimeter I

A scrap wood burning area and a fire training area are utilized at the site of the abantloncd airfield.

Two ordnance demilitarization (OB/OD) sites (see section 1.3.4.6 IHaznrdous Materials/Wastes [Bum Areas] for discussion).

For refuse disposal, JF’G maintains a contract with a private contractor for general pick-up, transport, and disposal of sanitary refuse. It is transported to a transfer station managed by the City of Madison.

J.3.4.5.12 Reaeation

The rural nature of the installation and surrounding region provides opportunities for disprrscd recreational uses. Hunting and fishing are the major recreation activities at JPC from the standpoint of both revenue production and user days available. It is estimated that over 6,000 user days/yc.ir are available for each activity for JF’G employees and other permitted civilians (USACE 1988). I-lunting seasons are established by the State of Indiana Department of Natural Resources (IDNR). l-lowevcr, Jl’G is permitted to deviate from regular hunting procedures through a Memorandum of Understanding with the IDNR: A state lottery system, where a few deer and turkey hunters are permitted to ncctw JK;, is subject to conditions specified in the MOA. .

3 - 66 In addition to the general hunting and fishing areas located throughout the I’roving Ground, land uses such as picnic areas, ponds, lakes and streams provide opportunities for passive rrcrc.1tion. Picnic areas are located at the ballfields and at Kmeger Lake. Camping also is available at Kruqer lAiki%.A quarter-mile jogging trail and ballfields are located near the family housing area. Kccrcntional fncililirs at Old Timbers Lake include developed camp sites, primitive camping, a boat ramp, and rental hont sites. All recreational activities at JPG, especially those of hunting and fishing, are available only on a limited and strictly controlled basis. DOD employees outside JPC are generally not permitted recreational privileges on post. However, active duty and retired military personnel do have recrwtion privileges. The general public may participate but only by means of a hunting lottery systrni or as guests of JPG personnel. DOD employees outside JPC are generally not permittcd recreational privilcgcss on post. However, active duty and retired military personnel do have recreation privileges.

Old Timbers Lodge is the most important recreation facility at JPC. A large limeslonc striicturc,, located in the northeastern sector of the installation, Old Timbers Lodge is important for its riistic qualities. It provides nearly 4,000 visitor nights per year for active and retired JIK personnrl and their guests. It can accommodate over 100 people at a time and is in excellent condition. The lodge also serves as a hunting headquarters during deer hunting season.

A listing of JPG recreation persondays during 1990 is provided below:

Fishing 6,000 Camping 4,000 Old Timbers Lodge 4,000 Small Game/Turkey 2,000 Softball, Tennis 1,m Sightseeing 900 Hiking 700 Picnicine 600 Total Person Days 19,200

Although there are numerous natural, passive, and active recreational areas such as campgrounds, golf courses, forests, many types of parks, and fish and wildlife areas located in the surrounding region, none are contiguous to or in close proximity to JPG. None would be directly affected by closure. Most off-post active recreational areas and facilities are primarily located in the Madison area of Jefferson County. Some of the more popular natural recreation areas in the region are Clifty Falls State Park (10 miles south of JPG along the Ohio River), the Ohio River, and Versailles State Park approximately 25 miles northeast of the JPG main gate in Ripley County.

3 - 67 1.3.4.5.13 Utility Systems

Electrical Power Svstem

Electrical energy needs are supplied to JPG by Public Service lndiana (PSI). In order to mtvt the needs of the ]I% operational and support mission, PSI provides power through four sepirate ovcrhcwi transmission feed points from PSI‘S North Madison substation. The largest feed circuit has a pottv~lial of 35.5 KV (kilovolts). The power provided PSI primarily serves the mnin firing line ,111~1 llic cantonment area feeds into an on-post substation from which electricity is distributed throul:h fivc 2.41)O volt radial feeders to a system of pad and pole mounted transformers. PSI also provides eleclricity for facilities in a northern portion of the test range along K-Road via a 12 mile feed from the I’Sl North Madison Substation. The on-post distribution system consists of the following componcnts:

Overhead Lines 265,142 LF Underground Lines 65,725 LF Transformer Capacity 5,124 JVA (kilovolt amperes) Substation/Switching Stations 1

PSI has considerable surplus electrical power capability reserves and doe not anticipate ntur-tcmn shortages.

The electrical distribution system, however, is considered to be obsolete and in need of significant modernization. At the time of closurenotification, JPG was taking steps to upgrade the system lhrough the gradual addition and replacement of component parts. The existing systeni has been thc cniisi’ of numerous problems regarding JPG‘s ability to accomplish current mission requirements in an efficient, cost effective manner. The age and general obsolescence of the system has been the cause of breakdowns, current fault areas, circuit overload, and increasing maintenance requirements.

The problem of age and obsolescence has been compounded with the steady increase of electric power requirements to meet the needs of the Amfs modem production ammunition acceptance testing program. In recent years JF’G has acquired new, more technically complex test equipment which have significant electric power demands.

Water SUDDIV

JPG purchases water from the City of Madison Water Authority through a service agreenitwt. ‘I hi, City’s water supply source are wells adpcent to the Ohio River. Water enters the installation .it (hte

3 - 68 22 via an eight-inch polyvinyl chloride (PVC) line which is connected lo a 500,000 gallon watrr tower located about 1.25 miles south of the JPG boundary.

The on-post water distribution system was constructed in the 1940s and services the cnntonnicwt ,iwa and the main firing line. Water required for many of the operational and support facilities in lhc range area is supplied by hauling it to various observation posts, safe houses, and firing points. 'i'hcw .ire il total of 108,401 linear feet of water lines on the installation. Although well maintained, the syslcni is becoming antiquated and requires increasing maintenance efforts. The primary problem iirw of Ihv system is the lack of a valve isolation system and system-wide cathodic protection.

The Madison Water Authority has a maximum production capacity of approximately eight million gallons per day (gpd). Overall system demand for the Authority's service area averages apprnxirnatrly 2.85 million gpd. Demand at JPG has remained generally constant in the 1980s for both domestic and industrial water requirements. Usage has ranged, onaverage between 30,000-40,000 gpd. The donwstic demands of civilian personnel (none of whom live on-post) and the on-post military residents living in the 13 family housing units make up the bulk of JPG water utilization; industrial requiremtrnls cmisist primarily of water needed to supply JPG's steam heating system. In 1990, a waterline was constructvd in the north end of the property supplying water to Old Timber Lodge. JPC purchases this wati'r from the Canaan Water Company.

Heatine Svstem

Heat is supplied to JPG facilities through a #2 fuel oil-fired central heating system. The existing system consists of four high pressure steam generating stations, each of which have a separate network of steam and condensate return lines. Two of the four plants are operational: the Central heating Plant, which serves most of the occupied on-post buildings, and a plant serving the Building 600 complex (ammunition assembly). Each operational plant is well maintained and in good operating condition. The 13 family housing units are equipped with individual #2 fuel oil-fired furnaces.

Number 2 fuel oil is stored on-post in an underground storage tank (UST). There are a total of 49 #2 fuel oil tanks with a capacity of 351,300 gallons; current utilized capacity is approximately 175,300 gallons.

J.3.4.6 Hazardous MaterialslWastes

The Enhanced Preliminary Assessment of JPG (USATHAMA 1990) identified 36 Solid Waste Management Units (SWMUs), and ten other areas requiring environmental evaluation (Figurr 1.3.4-7) (Joshi, personal communication, 1990). A Solid Waste Management Unit according tn .the USl(l'A's

3 - 69 RCRA Facility Guidance Document is defined as any discernible waste nianagcinmt iinit at a IKXA facility from which hazardous constituents might migrate, irrespective of whether the unit wiis iiitriidcd for the management of solid and/or hazardous waste, and regardless of the time at which 11ic. w.ist, was placed in the unit.

A summary of SWMUs and the areas requiring environmental evaluation, including ii diwriph)n, suspected contaminants, conclusions and recommendations as reported in thc Eiilriincrd I’rc4imin.iry Assessment is attached in Appendix J. Additional investigation and environnicntnl ~llarnrl(,ri~.ilioiiwill be required in many more areas on the installation. The permit status and spi’cilic awiw of known environmental concern including industrial operations, landfills, UXO, DU r[llit;ililili~iti[iii,l’<:l5- containing oils, asbestos, underground storage tanks, radon gas, and lead bascul paint, solvc.nl ilis~ximl areas and bum areas are discussed in the following sections.

Several of the sites that have been identified in the Enhanced Preliminary Assessment arc rc~gtrl.ikd under various state and Federal regulations and will be required to be addressed rcgardlcss of hnse closure. An overview of the environmental restoration for JFG is provided in Section 2.2.4, llase Realignment and Closure Environmental Restoration. The major permits and associated activities are summarized below (USATHAMA 1990; Joshi, personal communication, 1990).

Permit Status

Activity

I. Resource Conservation and (1) Open burning of propellants and open Recovery Act (RCRA) permit; detonation of explosives - Part B (Part A Interim and Part B (2) Storage of hazardous waste - Part A, Interim application submitted November 8, 1988)

2. Open Buming Permit and open Bum excess propellants/pyroteclinics detonation permit; (State Variance) and detonate explosives

3. Air Permit (State Variance); Burning of vegetation and scrap wood

4. Fire Training Permit; Fire fighting training (State Variance)

5. National Pollutant Discharge Discharge of treated sanitary sewi1k;r

3 - 70 LEGEND

licadquarters JPG 026 0 SWMU (Solid Waste Management Units) JPG 024,025 t N U 0 mi. Inu

JPG 019 /

JFG 017

JPG 012

JPG 029

JPG 010

JPG 028 / JFG 005

(Sourn: USATHMA.

Figure J.3.4-7. Location of Solid Waste Management Units and other areas requiring environmental evaluation.

3 - 71 Elimination System (NPDES) Permit; (State Permit)

6. Landfill operating permit; Disposal of non-hazardous, noli-sanitation wiistv (State Permit) and asbestos to Gate 19 landfill

7. Special waste State approval PCP contaminated wooden pnllets, ii~~ii-li~i~.ar~i~~iis, non-traditional solid waste, etc.

8. Nuclear Regulatory Commission Depleted Uranium License

A RCRA Interim permit (40 CFR 265, May 19, 1980) was required for propellants, explosives, and pyrotechnics (PEP) thermally treated at the facility. For example, a 12.5-acre themial treatmenl unit (JPG-023) operates under a RCRA, Part A, Interim Status permit for underground and above ground detonation. An Open Burning Permit from the Indiana Department of Environmental Management is required to bum excess propellants and explosives (State Variance), until a RCRA Part 13 Permit is issued by USEPA and the State of Indiana Uoshi, personal communication, 1990). The stale variance is renewed annually. Once the RCRA application is approved and the RCRA permit is issued, JIC will not require an annual variance from the state, except for burning of vegetation and scrap wood.

A renewed "DES permit required to discharge effluent from the sewage treatment plant has bee. issued by the State of Indiana for 1990-1995 Uoshi, personal communication, 1990). A Fire Training Variance allows for the training of personnel in fire fighting. The variance is renewed annually. JI'G was issued a license in 1984 from the NRC for the use of depleted uranium armor piercing projcctiles. This license was renewed in 1989 for five years.

Industrial herations

There are no mapr industrial operations at JPG. However, a wide assortment of munitions and ordnance have been tested at JF'G; these include propellants, mines, ammunition, cartridge cases, artillery projectiles, mortar rounds, grenades, tank ammunition, bombs, boosters and rockets. There are 268 gun positions, 50 impact fields, 13 permanent test complexes, and seven ammunition assenihly plants. In addition, numerous support operations and facilities use toxic or hazardous materials and generate hazardous waste products requiring recycling or proper disposal. These include: weapon maintenance, inert weapons processing, vehicle and heavy equipment maintenance and repiir shops, a central heating plant, paint shop, incinerator, small equipment repair shop, pliotograpliic .iiid watrr quality laboratories, and INANC operations and training areas. Training areas include an air-to-groiind

3-72 gunnery range used by INANG and a fire training pit used by ]PC Fire Departn1i:iit (Joshi, pcwotial communication, 1990). Each of these support facilities stores a supply of the ordnance, chrmic;iIs or fluids required by its operation, as well as an accumulation and storage area for the products/wastrs generated. A description of the suspected contaminants and associated releases are listed in Apprniiix J.

Active and Abandoned Landfills

The Gate 19 Landfill (JPG-015) is a 12-acre active landfill used for disposal of asbestos iind construction debris. In the past, large quantities of 1,1,1 Trichloroethane, paint thinner, and incrt filler containing methylene chloride have been disposed of at this landfill (Joshi, personal communication, 1990). Seven monitoring wells were installed from 1981-83 to determine if contaminants have n1ii;r;ilc.d from the landfill to the groundwater in the immediate vicinity. Twelve additional wells were installed

at various depths in 1988 to quantify water quality differences with depth. Annual sampling of thcs Cat(, 19 Landfill wells was recommended to detect potential groundwater contamination. Analytical rtwlts of sampling performed in October 1988 indicate that acetone (27ug/l) was present in groundwatrr. 'l'hc result of earlier sampling in July 1988 showed the presence of bis(2-ethylhexyl)phthalate found commonly in plastics. These could have come from the PVC piping in the monitoring wells or tlirough laboratory contamination, Sampling analysis to date indicates that there is no evidence to suggest contaminants have migrated offsite (USATHAMA 1990).

Abandoned landfills include sites JPG-005, JPG-017,JPG-024, JPG-025 and JK-026. These landfills have been used in the past for burial of inert and/or unexploded munitions containing hazardous constituents and heavy metals, solid wastes and refuse.

UnexDloded Ordnance (VXO)

Based on the evaluation of historical and current practices, JPC potentially contains UXO virtually anywhere on-site. Unexploded projectiles have been identified both north and south of the firing line and throughout the facility (Figure J.3.4-8). According to the JPG estimate (IDEM 1989), approximati~ly 23 million total rounds have been fire down range since 1941. Of these, approximately 1.4 million did not function and are considered duds. Approximately 6.9 million more were inert projectiles, although these items may have been fired with live fuzes and spotting charges. The majority of the unexploded rounds have not been recovered from these areas. The presence of UXO represents not only the hazard of detonation if disturbed, but groundwater contamination could result if cracked shell casings release high explosive chemical constituents and white phosphorus. Unburned white phosphorus can rcmain viable under the ground for many years. UXO is the greatest hazard north and south of the Firing LhL (USATHAMA 1990). A perimeter fence will be secured and maintained to prevcnl piiblic acivss ~iid

3 - 73 Minefield

1954and 1987

H Omi. Imi.

LEGEND 0Impact areas

Figure J.3.4-8. Approximate location of impact fields at JPG.

3 - 74 offpost land use encroachment, preserve public health and safety, and protect govcrnment property from illegal entry.

Sites JX-016 (water-filled pit) and JK-017(landfill) were used for disposal of tiitiiiilion.~:-r~~l~il~~~i components. The ordnance that is present may or may not be explosive. An abandoned wdI (IIY ;-OIX) contains lW200 riot control grenades. It is not known if these have explosive potrnliiil. In addition, a 12.5-acre thermal treatment unit located north of the firing line (JPC-023) is risrd .is iin olwn detonation area to dispose of spent or unusable fuses, detonators, primers, and grcnndrs. 'l'liis sit13 operates under a RCRA Interim Status Permit for under and above ground detonation. All of thiw sitvs may contain the explosive components including Trinitrotoluene (TNT),2,4-Dinitrotolucne (DN'I'), 2,6- DNT, Hewhydro-l,3,5-trinitro-l,3,5-triazine (RDX), 1,3,5,7-tetranitro-l,3,5,7-tetraazncycloocl;inc (1 IMX) and other explosive byproducts which are potential contaminants.

Deuleted Uranium (DU) Contaminated Area

Depleted Uranium rounds are fired north of the firing line (Figure 1.3.4-7). Since 19x3 more than 60,000 kg of low-level radioactive depleted uranium penetrators have been fired on a 2-square milv area (USATHAMA 1990). An estimated 25 percent (12,000 kg) has been recovered in the limited cle.inup conducted twice a year Uoshi, personal communication, 1990). The release mechanism causing polentiall contamination is the migration of uranium and radioactive decay products through the soil into surface and ground waters, and also potentially into the biotic system. According to monitoring rrsults, uranium has not been detected in surface or ground waters (USATHAMA 1990). Monitoring is rcqiiired under the NRC License to verify that no radioactive materials migrate off-site through air, water (including sediments) or wildlife. Monitoring of waters and sediments is performed every six months. Animal tissue is monitored once per year in conjunction with the annual deer hunts.

Although not required under the NRC license, the recovery and disposal of DU penetrators is performed to allow more penetrators to be fired within the amount licensed. The permit allows for 250,000 kilograms (kg) of DU to accumulate in the impact zone (Colonel Pearson, personal communication, 1990). When DU testing is no longer performed, a decommissioning plan will be submitted to NRC which specifies how DU contamination will be cleaned up and to what extent.

DU COUbtS of uranium metal of molecular weight 238 with low level radioactivity. The low level radioactivity poses an environmental concern. Uranium is also considered a toxic heavy metal. The principal radioactivity of DU is derived from the decay of the U-238, resulting in a 4.2 MeV alpha particle and a 0.5 MeV gamma ray. The radiation emitted from DU is not parliculnrly lxirnihil biologicafiy unless ingested and the toxicity of DU is probably inore harmful tliiin its riidioCwtivity.

3 - 75 Closure would require addressing concerns associated with radioactive decay, includin(: production of radon, as well as hazards from explosive ordnance.

Munitions Assembly and Testine Area

Several buildings in the southern part of the post near Firing Line Road are utilized for iisst~mhly of munitions. Although strict protocols are followed in munitions assembly, thr possihility of environmental contamination exists.

Areas where munitions have been tested, including the Cator mine testing arca, munitions tt-sting pond (JFC-019), and the rocket testing area, may be sources of contamination by hmvy nwtiils anti explosive residues. This area may also contain UXO representing an extreme physical hazard. '1'1~~arvzi of munitions demilitarization (JPC-013) may also be a source of contamination by heavy mctals and explosive residues and may contain UXO.

PCB-Containine Oils

A January 1989 inventory inspection indicated that all 252 transformers were in a "good" condition. The inspection did not indicate whether a leak of PCB contaminated liquid had ever occitrrtd. However, seven of these transformers contain levels of PCBs greater than 500 ppm. If these transformers are to be disposed during closure, given the high levels of PCBs, it must be done in accordance with the Toxic Substances Control Act (TSCA) and 40 CFR Part 761 rules. Twenty-nine (24 PCB-containing small capacitors are present at JPG.

Asbestos

Several of the buildings at JPG are made with construction materials that contain asbestos. Some of these construction materials are pipe insulation, roof shingles, and siding. A preliminary survey conducted by JPG personnel indicated that the total length of pipe insulated with asbestos is approximately 197,000 linear feet (USATHAMA 1990). Asbestos shingles and siding accounl for approximately 258,000 additional square feet. More than 75 percent of the asbestos-containing matcrials have been surveyed Uoshi, personal communication, 1990). The piping insulation and shingles are in good, bound and non-friable condition. However, there are many piping joints (union, elbows, etc.) in every building which have potential for friable asbestos. These piping joints must bc encapsulated to eliminate potential hiable asbestos. Asbestos presents the most significant potential for hazard when friable, or in a state that can be easily crumbled. JFC has been encapsulating the potentially friable asbestos in the piping joints in the following order of decreasing priority: Family Quarters, office

3 - 76 buildings, and workshops. JPCrecently removed 744 feet of piping insulation asbestos contnincd iii Ilw airport hangar that was in a friable condition.

Currently, JPG utilizes the Gate 19 Landfill QPC-015) as a permitted disposal site for [i[~~il~l[~-h,i~~~~[.~~ asbestos materials. The double-bagged asbestos is buried in three-foot deep excavations within tlw northwest comer of this 12-acre landfill. Asbestos is disposed of with allowance of the Slatti I’mnit. No reasonable estimate of the amount of asbestos disposed of at the landfill is availahlr; Irowcvcr, Iusd on the number of buildings that were renovated, the amounts disposed of coiild be large.

Undereround Storaee Tanks

Currently, there are 54 Underground Storage Tanks (USTs) constructed of materials ranging from bare steel to coated steel, located at various sites at JPG (USATHAMA 1990). The contents of the USl‘s include fuel oil, diesel oil, leaded and unleaded gasoline, kerosene, and white gas. The tanks were installed between 1941 and 1955, with capacities ranging from 300 to 25,000 gallons. It is possiblv that some leakage of tank contents into surrounding soils, and possibly groundwater, has occurred. JIY; has undertaken a program to ensure compliance with various Federal, state, and local regulations. JIY; closed 10 old, inactive tanks in October, 1988. Soil samples collected from these 10 tanks indicatcd total petroleum hydrocarbons in the range 400-4400 ppm. JPG tested all six 25,000 gal active tanks in Jtinc, 1990 and they were found not to leak Qoshi, personal communication, 1990). JPC maintains inventory reconciliation and uses the dipstick method for leak detection in the remaining small-sizd tanks. fly February, 1991, all inactive USs at JPG will be closed. The 40 active USTs will eventually he closed as required under applicable state and Federal guidelines.

Radon Gas

The presence of Radon gas is a ~tudlyoccurring phenomena and can potentially exist in any of the buildings at JPG. To date, 7day, 9(klay and 12-month testings (three phases of testing) for background radon gas concentration have been completed at the family quarters, building basement and shelter tunnel facilities on the installation. At all these locations, the background levels were detcctLul at much lower levels than USEPA’s action level of 4 picocurie/liter (Joshi. personal communication, 1990). Therefore, no further action for Radon testing or mitigation is required at JPC.

Lead Paint and Lead Oxide in Inert Filler

Lead surveys have not been conducted at JPG, however, several buildings at JPC were reportcdly painted with lead paint. Gate 19 Landfill could have potentially been used to dispose empty Icad pint

3-77 containers and paint sludge from Bldg. 136-Paint Shop in the 1970s. Lead can leach into thr grotiiid water and is hazardous to human health when inhaled or ingested in small quantities.

JpC-009 was used for red lead used in inert filler (weapons) that containcd 60% lead oxiclc by weight. Previous studies reported JPG-009 as a potential hazardous waste disposal site. I lowwcr, repeated visits have been unable to identify this site (USATHAMA 1990). Suspected red lead disposal sites may include the Gate 19 Landfill (JPG-015), JPG-004,JPG-005, JPG-012 and behind Ihildings 202, 148 and 211. Red lead is a heavy metal that is mobile under certain conditions. The proccdure of using red lead (P60)in the inert filler was abandoned in the 1970s (Joshi, personal communication, IWO).

Solvent DisDosal

Varying quantities of spent l,l,l-Trichloroethane solvent have been dumped in four locations ((:ate 19 Landfill, Bldg. 279, Bldg. 602 and Bldg. 617) at JPG Uoshi, personal communication, 1WO). Approximately lo00 to 10,ooO gallons of the waste solvent was disposed of at Gale 19 Landfill from IclhO through 1980. The soil surrounding Building 279 is also a source of Volatile Organic Compounds (VOCs) contamination from the solvent dumping in the past. Additional arcas of known VOC contamination include Solvent Pit-Building 602 uPG-027). Building 617 (JPC-028). and possihly I ti(% Burning Ground UPG-014) immediately south of Gate 19 Landfill.

Bum Areas

Open burning of excess propellants and pyrotechnics, open detonation of explosives and open burning of scrap wood occurs at JPG. For munitions-related materials, only small batches are burnrd at a time under controlled conditions. The open burning of the propellants and pyrotechnics is conducted in steel pans near the southern border of the installation. Thermal treatment area (open burning) JPG-022 bum approximately 60,000 Ibs/year. The propellants contain nitroguanadine, nitrocellulose, nitroglycerine and other organic components (Joshi, personal communication, 19"; USATHAMA 1990). Open detonation of "duds" and small caliber ordnance is conducted at Shonk Farm located within the middle of the test range southwest of Impact Field 27,000 center (]IC-023. The explosives contain TNT, RDX, HMX and other organic compounds. The thernial treatment arcas JI'C- 023 (open detonation) and JPG-022 (open burning) operate under an USBPA HCRA Part A pcrmit (Interim Status) and variances from the Indiana Office of Air Management. The Cator Mine Hurn Arca and airport runway area are used for burning of scrap wood Uoshi, personal communication, 1990).

3 - 78 SECTION Y - WMA PROVING GROUND

Y.3.1 NATURAL ENVIRONMENT

Y.3.1.1 Climate

The Yuma Proving Ground (YPG) is located within an and desert area charactcri7.cd by ahinddtit year-round sunshine. Summer high temperatures frequently exceed 110-F and winler lcmpvr,ltitrc*s range up to 85 degrees. Freezing temperatures are rare. Rainfall averages approximately 3.6 inchrs pcr year. Rainfall comes both from July to September and from November through February. Wind s~xvds are generally low at YPG, averaging 4 to 12 mph. Afternoon gusts up to 30 mph occiir frirliwiikly on the average of five days per month. The prevailing wind direction is northwest during tlic win1c.r iitxi southwest during the summer (USACE-LA and Michael Brandman Associates [MRAI 1987).

Y.3.1.2 Topography

The terrain at the YPG consists of large areas of alluvial fans surrounded by rugged hills and mountains. Approximately 40 percent of the area at YPG consists of rugged mountains and hills which have been deeply bisected due to heavy flash flooding over the years. The mountains are northwest- southeast trending linear ranges with maximum elevation of 2,822 ft. These mountains are comprised mainly of schist, volcanics, and other miscellaneous rock types. The lowlands are compriscd of coalescing alluvial fans or bajadas which are filled by sediments from existing mountains. The siirfaccs are flat to gently sloping and are crossed by numerous shallow washes and are dotted with occasional patches of desert pavements, wind-blown sand, and an occasional major wash. Figure Y.3.1-1 provides a generalized portrayal of topographic features within the study area.

Y.3.1.3 Geology and Mineral Resources

Y.3.1.3.1 Geology

Bedrock mountains form the more elevated areas of the YPG and consist of volcanic rocks and Quaternary basalts; gneissic and schistose rocks; and sedimentary and metamorphosed sedimentary rocks (Figure Y.3.1-2) (USACE-LA and USAYPG 1987; USACE-LA and MBA 7987). The bedrock occurs throughout approximately one-fourth of YE.Volcanic rocks make up to threequarters of that bedrock. Granitic, gneissic, and schistose rocks occur in next highest abundance. Of the bedrock, the sedimrnlary and metamorphosed sedimentary are least abundant of the three types of rocks.

3 - 79 3-80 BEDROCK MOUNTAINS Volcanic rocks

.. Grantitic, gneissic, .. and schistose rocks Sedimentary and metamorphosed sedimentary rocks

ALLUVIAL LOWLANDS Sand surficial materials Gravelly surificial 0 materials

Source: (USATHAMA) 1980

Figure Y.3.1-2. Generalized distribution of surficial material, YPG.

? - R1 Unconsolidated Quaternary alluvial deposits are characteristic of the remaining lowlands kir,iiniipx areas) and make up the majority of YPG. The Quaternary deposits are comprised of sand, silt, clay, gravel, and boulders. These alluvial lowlands consist of unconsolidated niatcrials and wr.ilhcrc.r. bedrock such as sands and gravels. Desert pavement (wind-polished rock fralgmcmts with grcntcr than 40 percent gravel cover lying on a fine soil horizon) occurs as a thin layer over portions of the flat areas, in addition to some of the low-rounded hills.

Evidence of volcanic action is present in the Chocolate and Middle Mountains ol llie West Arni ,ind the Tank and Palomas Mountains on the Fast Arm. Other areas consisting of volcanic rocks inclirdc~the Trigo and Mohave Peak Mountains in the West Arm and portions of the Castle Dome Morintiiin.; and Red Bluff Mountains on the Kofa Firing Range. The majority of the West Arm (norlhwcst and southwest areas) consist of granitic, gneissic, and schistose rocks. Sites with these typcs ol rocks include: south of the Dome Rock Mountains; south of the Trigo Mountains; the west cdge of the Middle Mountains; and the north portion of the Red Bluff Mountains of the Kofa Firing Range. The Dome kick Mountains are primarily composed of sedimentary and metamorphosed sedimentary rocks. Thr wi-stc*rn edges of these mountains consist of Bouse exposure formations which includes calcareous tuff and siltstones and sands and silts. The southwest comer of YPG near the Laguna Mountains is also made up of sedimentary rocks that includes sandstones, conglomerates, and silt stones.

Even though no active faults occur on YE,the area is prone to seismically induced groundshaking from nearby faults, primarily in the Imperial Valley of California. Additionally, localized areas within YI'G may be prone to unstable soil conditions such as expansive soils.

Y.3.1.3.2 Minerals

Historically, mining for precious metals, such as gold and silver, began approximately in 1863 and continued until 1942 when YPG was formed. After 1942, mining for these metals lessened while mining of uranium and manganese increased. Although the area is highly mineralized, insufficient quantities prevent sustained exploitation. Yuma County was a high producer of minerals around the turn of the century but currently only supports a comparably small number of mines (USACLLA and USAYI'G 1987; USACE-LA and MBA 1987). Additional metals found around the Yuma area include cadmium, antimony, beryllium, copper, lead, mercury, titanium, tungsten, vanadium, and zinc. Some non-metals include barite and fluorite. In addition to gold, silver, and manganese, copper, lead, zinc, barite, and fluorite may be exploited due to their abundance if economically viable. The other minerals either occur in insufficient quantity or size lo be exploited or they are associated with the primary minerals (USACE- LA and USAYPG 1987; USACE-LA and MBA 1987). Gold deposits are usually too disseniinatcd to justify exploitation. Some concentrated deposits of gold occur as placers in washes and lerraccs .ilong hills and were a result of Mesozoic rocks eroding prior to placemenl of volcanic rocks. .

3 - 82 Y.3.1.4 Paleontology

Much of the surface area in and around the YPG consists of Miocene Lacustrine deposits. Vrrldmtc fossils of the Lower Miocene have been reported from an area in the eastern Muggins Mountains (Olmsted et al. 1973). The hills and mountains of the area consist primarily of non-fossiliferous igncwris and metamorphic rock. Some poorly preserved gastropods have been found in a mudstonc of thr iippcr member of the Miocene Kinter formation and mollusks and foraminiferal faunas have been found in the older marine sedimentary rocks. None of these fossils are age diagnostic and arc not cotisidcnd paleontologically sensitive. The Pliocene Bouse formation is known to contain foraminifera, gnstropocis, pelecypods, and ostracodes. These invertebrates indicate a brackish to marine environment but arc not age diagnostic. The site for the JPG/WG transfer, however, lies on Quarternary Valley fill wliicdi is devoid of fossil remains Wander Zyl, personal communication 1990).

Y.3.1.5 Soils

The Soil Conservation Service has classified the soils on the YPC as hyperthermic arid with

Y.3.1.6 Water Resources

Y.3.1.6.1 Groundwater

Groundwater depths are based on the water depth of 13 wells drilled at various locations at the southwest comer of YPG (Entech 1987). Water depths generally range from 163 to 750 feet with two wells at a depth of 30 and 35 feet at the Main Administrative Area. The groundwater flows south- southwestward to the Gila and Colorado Rivers. The gradient flow is nomially 5 to 15 feet per niilc for the Kofa Firing Range and the southwest portion of YPG. Historically, infiltration from thc Gila and Colorado Rivers were responsible for most of the groundwater recharging in the Yuni'i area.. I lowwcr,

3 - 83 3-84 3 - 85 + miles Harqua-Perryville- Collidge-Wellton- ilGunsight Antho ...... _..:: .. :. jGilman-Vint-Brios...... Lomitas-Rock .::._:. .. Outcrop

,ource: (USATHAMA) 1980

Figure Y.3.1-3.General soil associations, YPG.

3 - 06 more recently, increased irrigation and the construction of reservoirs on these two rivers ha5 ?ilirti in diverted water from the Colorado River being the main source of ground watcr rcch.irgr (U~

Older and younger alluvium and windblown sand form the upper main groundwater rcwooir while the lower "poor-water bearing" rocks consist of non-marine sedimentary rock, volcanii : . I ,. older sedimentary rocks, the Bouse Formation, the transition zone and the conglomcrale nicmtici OI ..I*

Chocolate Mountains (USACE-LA and MBA 1987). Based on analyses prepared hy Enttrli (198' :~1::' groundwater within YEis quite mineralized and does not meet Federal drinking water stantl;iI-,. fluoride. This condition is due to naturally occurring minerals within tlic soil.

Y.3.1.6.2 Surface Water

The majority of annual precipitation occurs from August through September as a rcsiilt CI~ thundershowers. The high daytime temperatures and low relative humidity results in high evaporaticin rates and thus low surface water accumulation. All of the existing stream and drainage channi-Is flov, south or southwestward toward the Gila and Colorado Rivers. Permanent natural water sources, such as lakes and streams, are absent within the WG boundaries. Infrequent rainfall can producc ~milizcd flash-floodingand temporary surface water. Although few permanent natural water sources are present, various man-made water holding structures have been installed to increase water sources for wildlife.

Palmer (1986) identified three types of water sites on YPC: Tinaja - a naturally occurring hole within usually scoured bedrock that are usually found in mountain canyons; enhanced tinaja - these are tinajas that have been artificially improved to increase and prolong its water storage capacity (some of :hesc may retain water throughout the year); water catchments - a 5,700 to 132,500 liter aluminum or concrete storage tank constructed by Arizona Game and Fish. Many of these water sources exist on the West Arm and are shown on Figure Y.3.1-4.

The McAllister Wash and Indian Wash of the Cibola Range and the Castle Dome Wash of the Kofa Firing Range, all major drainages, are ephemeral streams with streamflow occurring during and immediately following rains. McAlliter and Indian Washes drain south-southwest to the Colorado River and the Castle Dome Wash drains south through the Kofa Firing Range towards the Gila River. Each of these washes contain numerous smaller channels which may change their course during niapr flood events. Several permanent water sources exist outside of the YPG boundaries. The Gila and Colorado Rivers lie south and west, respectively, of YPG. Mittry Lake, Martinez hke, Squaw I,ikc, Imperial Reservoir, Ferguson Lake, and Senator Wash Regulating Reservoir all occur along the Colorado River, west of YPG (USACE-LA 1986; Entech 1987). .

3 - 87 1 '0 I l5Oo1* I' I-'- 1:bl I 04 i l4 I

I I I 30 09 50 I I 2d I I 013 ; I 70 I I I

L I ,1-- I 1 r.r-- I I

0 10 I t I

Figure Y.3.1-4. Arizona Game and Fish Department watering sites on WG.

3 - 88 Y.3.1.7 Aquatic Ecology

Since surface water sources on YPC are limited to stock tanks and similar structures, therr iire no notable aquatic biological resources.

Y.3.1.8 Terrestrial Ecology

Y.3.1.8.1 Description of General Biological Resources at YPG

Vegetation

The plant communities on YPG are described collectively as characteristic of Sonoran dc-serl scrirb, a floristic region that encompasses southwestern Arizona, the Baa peninsula, and portions of Southeastern California and northwestern Mexico (Turner and Brown 1982). Summer and wintrr rainfall, as well as evolutionary origins of many species in the subtropical regions of Mexico and South America, contribute to the large diversity of annual and perennial species found in Sonoran desrrl scrub. The predictable bimodal rainfall pattern distinguishes the region from the reliable winter/cwalic summer rainfall pattern of the Mojave desert to the west, and from the less arid Chihuahuan desert to the east.

Sonoran desertscrub on YPG can be subclassified into three plant communities, depending on the relative frequencies of grasses, shrubs, and cacti: creosotebursage, paloverde-mixed cacti, and grassland. Paloverdemixed cacti occurs at higher elevations than creosotebursage, generally above 2,500 fwt. lhe desert grassland community is interspersed between the paloverde-mixed cacti and creosote-bursage communities in portions of YPG, occurring in alluvium and areas of wind-dispersed sand (loess). Within each of these three communities, local variation in topography and soil Composition can result in particular associations of species (Brown 1982; Turner and Brown 1982; Ough and de Vos 1984; USACE-LA and USAYPG 1987; USACE-LA and MBA 1987).

Appendix K lists common plant species on YPG and the Sonoran desert scrub communities or associations in which they occur most frequently. It should be noted that the vegetation inventory of YPC is incomplete. Vegetation maps have been prepared for the West and East Arms (Figures Y.3.1-5 and Y.3.1-6) but not for the south central or Kofa Firing Range portions of YPC. There is a substantial amount of information on perennial species (shrubs, trees, and cacti) for the West and East Arms. but information on the distribution and composition of the annual communities in those areas is relalively limited and confined to locations at which the broad-scale ecological studies were conducted (0iq;h and de Vos 1984; USACE-LA and USAYPG 1987; USACE-LA and MBA 1987). .

3 - 89 -- - Study Area Boundary . I Figure Y.3.1-5. Distribution of plant assodations, West Arm of WG

3-90 APPHOX. SCALE

Source: Arizona Game and Fish Departme

Paloverde. mixed Cacti, Ironwood and Smoketree associations

0 Study Area Boundary dI' - - .

Figure Y.3.1-6.Distribution of plant assodations, East Amof MJG.

3 - 91 There have been efforts to compare the communities described below in terms of spcyies divwsily, diversity in height of the foliage, and other factors that are considered to be important for wildlift, iin? wildlife management. These data are presented in Ough and de Vos (1984) and de Vos and Oicg. (19861, and summarized in later reports (USACE-LA and USAYPG 1987; USACE-LA and Ml3A 1987). Little data are available for the Kofa Range.

Creosote-bursage Community: This community is classified within the Lower Colorado Nver Valley subdivision of Sonoran desertscrub (Turner and Brown 1982). The community doininntes cliw,itions under 3,000 feet and is exposed infrequently to freezing temperatures. On YJ'G, the creosote-bursage (Larrea tridentata -Ambrosia dumosa) community can be dominated by those two spccies or can include additional co-dominant species. Thus, three major types of associations within this commiinity are recognized on YPG aeosote-bursage, creosotebursage-ocotillo (Fouquieria splendms), and crcosote- bursagefoothill paloverde (Parkinsonin microphylla). Diversity and densities of perennial plant species are relatively low in all three associations, but abundance of annual species in terms of pcrcent rnver can be high, especially in the creosote-bursage-ocotillo association. The creosote-bursage community as a whole is common on YPG, although the three associations that are recognized as part of this community vary in distribution according to topography and soil composition. Creosote-bursagc! occurs primarily in flat watersheds above washes and in desert pavement. The creosote-birrsage-ocolillo association tends to occur more frequently on rocky slopes. Creosote-bursage-foolhill paloverde occurs primarily in washes.

Paloverde-mixed cacti: This community is part of the Arizona Upland subdivision of Sonoran desertscrub (Turner and Brown 1982). Three associations of dominant species are recognized within the community: foothill paloverde-saguaro (Cereus giganteus), foothill paloverde-ironwood (Olncyg tesota), and blue paloverde-smoketree (Purkinsoniu florida-Dalen spinosa). One or more species of cholla (Opuntin spp.) and hedgehog (Echinocereus spp.) cactus can occur in all of these associations. The lotlthill paloverde-saguaro association occurs primarily on mountain slopes, away from washes and valley floors. The foothill paloverdeironwocd association occurs most frequently on bajadas and along washes, but because ironwood is more sensitive to frost than foothill paloverde, the species may be absent from the community on north-facing bajadas and cold valley floors (Turner and Brown 1982). The blue paloverdesmoketree association occurs in mapr washes where there is a relatively greater amount of available water. The paloverdemixed cacti community is well-distributed across mountain slopes, bajadas, and major washes of the East and West Arms of YPG.

Desert Grassland: This community is dominated by galleta grass (Hilaria riginn), either alone or in association with a few other grass species (e.g., three-awn, Arislidn spp.), shrubs, or trers. The community occurs primarily in areas of winddeposited sand (loess) and alluvium. Two associations

3 - 92 of dominant species are generally recognized on YPG: galleta grass-foothill palovcrde and gnllcta }:ross- mesquite.

The grassland community is limited in distribution on YPG. The galleta grass-foothill pnlovi*rdr association is found most frequently in sand dune formations, and galleta grass-mesqirile is hind primarily in loess or alluvial areas between the foothill paloverde-ironwood and crcosotc.-hiirs;ij:r associations.

RiDarian Scrub: This community is classified separately from Sonoran dcscrlscrrrb iind is not described in previous reports. It is confined to the immediate vicinity of a few ponds constriiclvd by humans for wildlife management or other purposes. Plant species composition varirs with location and has not been described in prior studies. Species observed during Chambers Croup, Inc. visils to two ponds in the east central portion of YPG includesaltcedar (Tamarix spp.) and saltgrass (Dislichlisspicnta).

Vertebrate species found on YPG are primarily associated with arid desert scrub habitats. In addition, the relative proximity of the Colorado and Gila river systems on the west and south borders of the site, respectively, increases the diversity of some vertebrate groups. This is particularly truue for migratory birds, which will frequently utilize riparian and wetland habitats peripheral to rivcr drainages. Although YPG may not include wetland habitats, it is associated with northern migratory comdors and, as a result, over 60 percent of the bird species known to occur or potentially occiir on YPG are seasonal residents, either as breeders in spring/summer or as winter migrants. Furthermore, planned or incidental irrigation practices on YPG, including runoff seepages and lawns/gnrdens, may attract casual migrants.

Despite its large size, the dominance of relatively low elevation arid habitats on YPG limits the diversity of some vertebrate groups. Though nearly 40 percent of the total surface area of WC is montane (including canyonlands and rocky slope topography), the maximum elevation is 2822 ft (860 m). Therefore, vertebrate species commonly associated with higher elevation vegetation communities, such as pinyon-juniper, are not found on YPG. This would include some smaller mammal species, and a variety of passerine bird species which utilize elevational migration routes on higher mountain slopes in other areas of the southwest. Furthermore, the lack of permanent surface water (e.g., lakes and perennial streams) on YPG limits the number of amphibian, freshwater fish, and aquatic bird sprries.

AmDhibians: The predominant amphibian species known to occur or potentially occur on YIY: arc those species which have adapted to arid environments with no perennial surface water. 'll\c nu~st.\rid adapted amphibians on YPG are the spadefoot toads (genus Scaphiopirs). Membcr of this jyniis will

3 - 93 remain dormant underground until temporary surface pools become available. At this tiinc., Iliv imlirc reproductive process, from courtship to the metamorphosis of juveniles, can nccur iii thc spin of onll. several weeks. Other amphibian species which occur or potentially occur on YI’G, such as the Sonw~r~ desert toad (Bufo alvarius) and the red-spotted toad (Bufo pundatus) are limited to wettrr habitats, such as those found in or near irrigation or in deep canyons. Introduced species, such as bullfrogs (Rutin castesbeiana) or tiger salamanders (Genus Ambystoma) may occur in artificial walcr storiigc facilities, recreational water, and/or drainages, as the larvae of these species are frequently used as fisliiiij: bait.

Reotiles: Reptiles are the most conspicuous vertebrate group on WG. The composition of a particular reptile species assemblage depends largely on substrate type within the Sonoran drscrtscrub. Another factor which influences the likelihood of encountering a particular reptile is limr of day. With one exception (the western banded gecko), lizards and the desert tortoise are diurnal (activ(, in the daylight hours). Snakes are almost exclusively nocturnal (night hours) or crepuscular (twilight). Open bajadas commonly support whiptail lizards (Cnemidophorus tigris), desert iguanas (Dipsosuurirs rl~~rsulis), and horned lizards (Phynosomn spp.). Snake species include kingsnakes (Lampropdlis p!fuftrs), y,iyhcr snakes (Piluophis melanoleucus), the western diamond back rattlesnake (Crotalus atrox) and the mojavc rattlesnake (Crotalus scutulatus). Zebra-tailed lizards (Cnllisaurus draconoides) and sidewinders (Crolalus cerastes) frequent washbottoms. Loose blowsand substrates exist in limited distribution on YPC. Snake species specializing in loose sand substrates include western shovelnosed snakes (Chionactus occipilnlis) and western blind snakes (Leptotyphlops humilis). Rocky slope substrates and bouldered terrain siippcirt several species of common lizard, including collared lizards (Crotophytus collaris) and chuckwalla: (Sauromalus obesus). Snake species found commonly in heavily bouldered habitats include night snakes (Hypsiglena torquafa),and several species of rattlesnake (Genus Crotalus).

-Birds: The bird diversity of YPG is extremely high, though seasonal. This is primarily due to the inclusion of the area as part of a seasonal northern migration corridor for North America. Unlike reptiles, local bird species diversity tends to be more closely correlated to the dominant vegetation in an area. Numerous passerine species occupy specific vegetation assemblages on YPG, particularly those habitats which include paloverde. Conspicuous species include rock wrens (Salpinctus obsoletus), wrstern meadowlarks (Sturnella negleda), and black phoebes (Sayornis nigricans). At night, common spccics include great homed owls (Bubo virgininnus), lesser nighthawks (Chordeiles acutipentiis), and barn owls (Tyto alba), particularly in association with old structures and irrigated lands, where they feed on rodents. Based on data provided by the LCTA studies in 1991, white wing dove, phainopepla, verdin, house finch and gila woodpeckers were the most conspicuous species observed on the Kola National Wildlife Refuge.

Mammals: The majority of mammals species on YPG are nocturnal, and thus generally inconspicuous. Two notable exceptions are black-tailed jackrabbits (Levus cnlifonricir?;), wliicli iire

3 - 94 coninion throughout WG. and ground squirrels (Genera Spermophilus and Ar~rfi~~s~~~r~fiop/iifi~~).Sin;ill nocturnal rodent species dominate the mammal fauna, and tend to bc associatcd with srihslratc. Kangaroo rats (Genus Dipodomys) are almost exclusively found in open, flat and spiirwly VI-~;&II~ habitats, whereas native mice species (Genera Perognathus and Peromysciis) inhabit niorc clwwd, rocky terrain. Mammalian carnivores are represented chiefly by coyotes (Cnnis Inlrrrris) which, though nocturnal, can be seen in late mornings and toward sunset. Smaller canine cariiivorc-s, iiidii~tiii~~):ray foxes (Urocyon n'nereoargenteus) and kit foxes (Vulpes macrolis), arc iiiore strictly noc~urn,iI.id crepuscular. Bobcat (Lynx rufus) and mountain lion (Felix concolor) also occur on YIC, with ini~iinl.iin lions generally restricted to less travelled rugged terrain. Large nlanlmals known to cxist on YI'C; include mule deer (Odocoileus hemionus), and bighorn sheep (Ouis canadensis), whosc home rCiiqysand migration routes have been described for the central montane regions in and near YPC;, in hbKofa Reserve. Wild burros and horses also occur on the facility.

A number of species commonly associated with more aquatic habitats may periodically be obwrvvd on WG due to its proximity to the Colorado River. Several species of ducks, egrets, and shorcbirck may be sighted in areas where surface waters are present, such as storage reservoirs. Killdeers (Clmrfulrius vociferus), though found under natural desert conditions on YPG, may aggregate In conspicuous numbers on watered lawns.

Suecies of Concern, Threatened and Endangered Flora

Federally-listed threatened and endangered species have full legal status for protection. Additionally, state listed species are recognized as sensitive by YPG. All other species are treatcd as sensitive, but do not have legal status by state or Federal law.

Veeetation: Table Y.3.1-2 lists sensitive plant species that are known to occur or potentially occur on YPG. There are no Federally or state listed threatened or endangered plant species known on the Yuma Proving Ground. However, one Federal Candidate species, two category 3C species, and one Bureau of Land Management (BLM)-sensitive species occur on WG. California snakewocd (Colubrina californica), Federal category 3C and BLM-sensitive, is known from southeastern California and scattered areas in southwest Arizona. Wiggins cholla (opuntia mgginsii, Federal category-2 and BLM-sensitive, has been found in the western and central portion of YE.Spiny sand spurge (Stillirigin spinulosn), 13LM sensitive, has been found at the south end of the West Arm. Night-blooming cercus (Cerws pyqii), .I category X species, is found at the northern portion of the West Ann. Although not previously recorded, two additional species, California barrel cactus (Ferocacfus acanlliodcs var ncanthmdm, I~cdcral 3C) and flat-seeded spurge (Chamaesyce platysperma, BLM sensitive, Category-2) iiiay also occur on Y IC due to available suitable habitat.

3 - 95 B 4 E

3 - 96 Wildlife: Tables Y.3.1-3 and Y.3.1-4 list wildlife species of special concern occiirring or potenti;illy occurring on the YPG, respectively. Gila monsters (Heloderma suspecfrrm), a ca tegory-3C sptrirs, prck washes and canyon bottoms with dense vegetation, as well as irrigated lands. Moiive fring(4wd lizards (Uma scopria), Arizona state candidate species, are restricted in distribution to Ioosc hluwsiind substrates which occur in limited distribution on WG. Rosy boas (Liclinnum Irivirpln), listcd as unconimon in Arizona, are found in dry, rocky canyons. The desert tortoise (Xirroln/i,sqwssizii), an Arizona state candidate species and a Federal category 2 species (in Arizona), is a suhstmk g(w,r,ilist, but is generally found on slopes and bajadas with rocky habitat used for dens and burrows. 'I'hc~sp.cii*s is listed as threatened in California, and is being considered for listing in Arizona by tlic U.S. I:ish and Wildlife Service. An individual osprey (Pandion hnliaelus), listed as Threatened in Arizona, hiis Ixscn observed on the eastern YPG. This species requires large bodies of water for a fisheries swrt'('. 'W individual sighted was probably a resident of the Gila River drainage.

The Yuma puma (Felix concolor brownii) is a Federal category 2 species as well as listed by Arizona as endangered. Although its taxonomic standing is still under debate, there have been sitings of pinias within the YPG area. Mr. Harvey Shaw (personal communication) of the Arizona 1)epartment of (hme and Fish believes that these sightings are of young individuals passing through. It is likcly LIwt thc animals sighted at YPG represent an overlap of two or three subspecies (John Phelps, Arizona (;;line and Fish, personal communication)

Bighorn sheep (Ovis canadensis), previously on the Arizona Threatened/Endangered Spvcirt. I ist, home ranges and migration routes have been described for the YPG and Kofa Reserve. Feral Iiorses (Equus caballus) and burros (Equus assinus), protected under the "Wild and Free-roaming Horse and Burro Act of 1971", are known to exist in small numbers on WG and surrounding areas, particularly the western portion (Ough and de Vos 1984). The leaf-nosed bat (Mncrotus californicus) and the spotted bat (Euderma maculatum) are both State Candidate Species.

Y.3.1.8.2 Description of Biological Resources of the Various Planning Regions at YPG

The majority of species information presented in this section is taken from the results of two studies conducted by the Arizona Game & Fish Department; Ough and de Vos (1984), and de Vos and Oush (1986). Additional information was extracted from various species surveys and personal communications. This section is broken down into three areas: East Arm, Kofa Firing Rangc (contral portion), and West Arm including the North and South Cibola Ranges, and the Main AdministriiLive and Mobility Test areas. Because each area is separated by arbitrary boundaries riithcr than spccific geographical/topographical.features,a high degree of overlapping occurs among the flora and hun'i. Extensivestudies have been conducted on the habitat/plant association preferences by various sptrcics of wildlife. The faunal discussion is based on the species recorded for each specific vcptation

3 - 97 3 - 98

3-100 tiwtc.isitioii for the arcas studicd by Arizona Game and Fish. Although thesc areas represent only a ~)oi~liiitiof tlic total YI'G, the flora/fauna associations may be applied throughout.

East Arm

Vcwl,ition: The East Arm, YPG, primarily consists of the paloverde-mixed cacti vegetative coininuniiy which includes the paloverde-ironwood and paloverde-saguaro plant associations. %a ttered ''pildic~s"of Lhc creosote-ocotillo association are also present at the north end and a relatively larger porLim at the southern end in the vicinity of the Palomas Mountains. Drainages originating from the pnlovcrde-ironwood and paloverde-saguaro plant associations provide narrow strips of the blue pnl~,verdc-smoketreeplant association. The Hoodoo Wash, which is located north of the Tank Mountains at the north end of the East Arm, provides a very high quality section of the blue paloverde- smoketree. association. Some of the common plant species found in these areas include saguaro, p,iloverde, white brittlebush, ocotillo, ratany, ironwood, muhly, California fagonia, wolfberry, catclaw, r.ibbitbnish, globemallow, and cholla.

Wildlife: The majority of faunal species occupying the East Arm are associated with the paloverdemixed cacli vegetative community. The more uniquely diversified habitats, such as the blue paloverde- stnoketrce plant association, would be expected to contain a larger diversity of wildlife species. The norlhwcst portion provides the highest wildlife species diversity of the East Ami. The Arizona pocket niousc and the rock pocket mouse are the most common small mammals in the steeper, rockier terrain and the desert pocket mouse is the most common on the more gentle slopes. Other small mammals that may be found throughout the area are the canyon mouse and the white-throated woodrat. The blue paloverde-smoketree plant association is the only plant association where Bailey's pocket mouse. The larger mammalian species (Le. coyotes, bobcats, and gray fox) are more readily found in paloverde- smoketree plant association and the paloverde-saguaro association which is common throughout the Ikst Arm. Large game species found on the East Arm of YPG include the desert bighom sheep (discussed under sensitive species) and mule deer. Highest utilization by mule deer in the East Arm occurs on the northern portion, particularly within the blue paloverde-smoketree lined drainages which I)fft,r ,idcquate cover and forage.

'I'lic tnountainous terrain found throughout the East Arm offers suitable habitat for a variety of avian sl)t,t,ic.s, tlic most dominant being rock wrens and black-throated spnrrows. These areas also support pol)ul,ilions of verdin, cactus wren, black-tailed gnatcatcher, western meadowlark, yellow-rumped wiirI)k*r,violet green swallow, white-throated swift, and the gila woodpecker. Raptors that may be seen iiii,liidcs the American kestrel, red-tailed hawk, sharpshinned hawk, and turkey vulture. The canyon wwti is specific to the paloverde-saguaro plant association and seasonal occurrence of phainopepla, .

3 - 101 mourning dove and white-winged dove may occur in the paloverde-ironwood association. In general, thc hluc paloverde-smoketree association offers habitat for numerous avian species.

This area supports only a low to moderate diversity of reptilian species due to the area's dominance by Ill(*oxisting Vegetation associations. However, a higher diversity of reptiles can be found along the 1A Arm drainages. Some of the more common reptiles that may be found are: western whiptail Iiziircls, haiided gt!!kos, side-blotched lizards, and desert homed lizards. Couch's spadefoot toad and thta };r(ut pliiiiis toad are common in the paloverde-ironwood association.

Sl'tricbs (if Coiici:rii: Information for habitat utilization by desert bighorn sheep was compiled throii};h Lwo studies, de Vos and Ough (1986), and Palmer (1986). The Tank and Palomas Mountain rciiig('s, located in the central and southern portions of the East Arm, respectively, provide moderate quality habitat for desert bighorn sheep. The Tank Mountains offer the highest usable habitat due to ~. tlic prcseiice of a permanent water source (White Tank). Important movement corridors occur between s the, Kofii/West Tank Mountains and the east Tank Mountains of the East Ami. Desert tortoise sign was observcd in the Tank Mountains and along the southwestern side of the Palomas Mountains.

Kofa Firing Range

Vcxctation: Information on vegetation communities and associations for the central portion of Kofa- Firing ILinge (KEX) is very limited. However, the eastern portion of the range is included in the Ea Ami stiidy (de Vos and Ough 1986) and is discussed in this section. In general, the KFR appears rel,ilivcly less vegetatcd compared to the East and West Arms of YM;, although little survey work has ~~cciirrcdin this area. The east portion of the KFR is dominated by creosote-white bursage and the p;iI[iv~rdc-ironwoodvegetation associations with small strips of blue paloverde-smoketrre lined dr;iin;iges. The area is relatively level with the Castle Dome Mountains extending into the northern pirticin (if the range and the Muggins Mountains extending into the southwest portion. The creosotewhite bursage association has low species diversity but fairly high productivity due to the occurrence of annuals. Species occurring in this area include: white bursage, brittle-bush, wire lettuce, teddybear cactus, ocotillo, and ironwood.

Wildlife: Information on the biological composition of the KFR is also limited. The east end of the riingc is included within the "East Study Area Wildlife Inventory" (de Vos and Ough 1986), and much of the following discussion is based on information from that report. Many of the species presented in this scction arc associated with the creosotewhite bursage and the paloverde-ironwood plant association which 'ire dominant throughout at least the eastern portion of the firing range. The KFR supports a iiiodt~r.itediversity of small mammals with the Arizona pocket mouse, the desert pocket mouse, and

tli{. MCTIi.iiii's kangaroo rats being the dominating species. Merriam's kangaroo rat is primarily found

3 - 102 iii llic 11at floodplain and desert pavement areas. Kit fox are common throughout this area and the iringt.iiI cat may occur in the extreme north boundary in the Castle Dome Mountains. Although the KFR ni;iy lie the least utilized by mule deer, this area does provide small strips of blue paloverde-smoketree dr

Sptricbs of Concern: As with the East Arm, the KFR provides a minimal amount of habitat for scwsitivc spccics. The Muggins Mountains, located at the southwest part of tlie firing range, do not provi(ic. suitable habitat for sheep; however, BLM has identified the south portion of the Muggins Moiiiitiiins rvceiving year-long use (BLM 1985). The Castle Dome Mountains at the north-central h~iiiid.iry,prrivides only moderate habitat and usedepends on the habitat quality and water availability oii ~hc..idjoining Kofa Wildlife Refuge to the north. Movement into and out of the Castle Dome Mf~iiiiuinsis dependent on the narrow corridor between the South Trigo Peaks and the Mohave Tank Mtwiit.iiiis. I:cml burros may occur in the east end of the KFR but in very low numbers. Burro sign h,is bccn obscrvid along the Wellton-Kofa Road extending from the Signal Butte area north-northwest towards the northem boundary.

Wesl Arm (North, South Cibola Ranees)

Vr~:ctation: Extensive ecological studies have been conducted on the West Arm by the Arizona ( ;ciineand lkh Department that describe both vegetation and wildlife. These studies, for the most part, were conducted on the North Cibola Range but can be extrapolated, in some instances, to apply to the cntirc West Arm. The most common plant communities and associations are the paloverde-saguaro, I'.ililvc.rde-ironwood, and creosote-ocotillo. High quality blue paloverde-smoketree washes occur in iiiodi~r,ite,imounts. Plant species recorded for the plant association for the KFR and the East Ami woiilil ciIw bc expected in the West Arm.

Wildlifc: Information on species composition and habitats for the West Arm is taken from Ough iind de Vos (1984) on a study conducted at the North Cibola Range; the habitats they occupy may be fouiitl throughout much of the West Arm. The creosote-ocotillo plant associa tion, found throughout IIic, Norlli Cibola range, supports a low mammal diversity but a relatively high abundance of those spvit's. 'l'hc most common small mammals species include the Arizona pocketmouse and the rock )io&cl mouse. Wildlife species previously listed for the East Arm and the Kofa Firing Range within thv p.iloverde-s.iguaro and paloverde-ironwood plant associations may also be expected to be found h*i(I 'l'lic nwst common avian species found in the creosote-ocotillo association is the black-throated spirtow. 0thi.r spccics that may be observed here are the cactus and rock wrens, house finch, gila w(io(lprckcrs and the loggerhead shrike. Reptiles that may be commonly found in the West Arm are Ill(. wt,,slc'rn whiptail, bandcul gecko, spotted leaf-nosed snake, and tlie desert collared licard. 'l'he North

3 - 103 C 11x11~1I<.ingc offers very suitable habitat for muledeer and supports the highest abundance on the YPG A i~iin~miiniof ten permanent water sources are located within the West Arm, most of which are in th ~~~n11~11.ind north portions.

C;j)t*(.ic*sof <'oncern: Night-blooming cereus is known from the northern portion of the West Arm ~- .~~idis found in creosote flats and bajadas east of the South Trigo Peaks Mountains. It has also been 1oiiiid also Mohave Wash and suitable habitat occurs over most of the base. The Wiggins cholla occurs '11 the* north end of the West Arm on sandy soils of small washes or flats in the Galleta-Mesquite plant -' .issociations. The California snakewood also occurs on the West Ann (North end) and has heen found on ~iiiiclywashes and rocky canyons in Crazy Woman Wash and Lopez Wash of the Trigo Mountains. - 51)iny s,ind spurge has been found at the extreme south end of the West Ami near tlie Main I l~~~~~lquiirtcrscomplex in sandy desert soil and the Hall shrub spurge is found along sandy washes or on rocky slopes and has been found in Weaver Pass on the Dome Rock Mountains. -

'I'liv West Arm is the most utilized area of YPG by desert bighorn sheep and primarily occupies the sti*tLpcrupper slopes of the paloverdesaguaro association. The Mohave Tank Mountains offer excellent siiitablc habitat for lambing and nursing grounds. The northern part of the Trigo Mountains, located on tlic~west boundary, include the largest continuous habitat for sheep on the YPC and the Mohave l'c~iks Mountains provide an important lambing area. The Chocolate Mountains provide suitable lambing and nursery sites and has been designated as having high use by Palmer (1986). The Middle,. IhIW Ikk, and South Trigo Peaks were evaluated as having low to moderate use and the North Trig I'cuks Mountains are used on a "transitory basis." Important travel corridors occur throughout the West Arm and the adjoining Kofa National Wildlife Refuge. Movement from the north portion (Dome Mountains) to the southern portion (Chocolate Mountains) is via the various mountain ranges in b(*lwc.cn (South Trigo Peaks, Mohave Tanks, and Mohave Peaks Mountains).

i)esrrt tortoise sign has been located south of Crazy Woman Wash in the Trigo Mountains, and '. individuiils were observed in the Chocolate Mountains. The Mohave fringe-toed lizard is restricted to fin(., loose sand and has been found along Bouse Wash. The northwest portion of the North Cibola l

li*r,il burros occur in highest numbers on the YPC on the West Arm, particularly the North Cibola l<,in}:c* in Lhr vicinity of Trigo Mountains, Mohave Peak Mountains and Crazy Woman Wash.

3 - 104 Individuiils have been observed on Hidden Valley, Chocolate and Mohave Tank Mountains in the

1j.1 Ii)v~,r~ii,-ironwood,pnloverde-snioketreeand creosote-ocotillo associations. Important travel corridors iii~diid(*the Mule Wash, Trigo Wash, weaver Wash, Indian Wash and Ehrenberg Wash.

M.iin I'osl Area

.Hiis area is located in the southwest portion of YPG at the south end of the West Arm. It includes tlic. v'irious sites. structures, etc. that occur in the vicinity of the Main Post (Mobility Test Area, Main Acliiiinistriltive Area, etch Due to the high use of these areas, it isdiscussed sepnrately as to the existing l)idq;ical conditions. However, very little biological information has been collected for this area. 'l'lic~~~*f~~rc,the discussion is primarily based on existing data for surrounding areas, as well as +;vncr.ilimd descriptions for YPC (USACE-LA and USAWG 1987; Ough and de Vos 1984,1986; Palmer I wb).

Vcrctntion: Vegetation associations identified for the North Cibola Range and the east end of the KoLi Firing Range are generally the paloverdemixed cacti and creosote-bursage.' Common plant species ici(w1ificd to occur within these associations should be expected to occur in this area and include hrilll~4~ushocotillo, ironwood, and wire lettuce. The major washes in this area may consist of mesquite, rtit,iiiy, and galleta grass. A botanical study was conducted on the Vinegarroom Wash (Higginbotham and Aswc. 1978) located in the general vicinity of the Mobility Test Area and 8 total of 21 species were idc!nlificd. Cheesebush, creosote bush, and sweetbush were most common and brittlebush, burrohush, diamond cholla cactus, ironwood, paloverde, squawberry, and saguaro were found in somewhat lesser ainiounts. Other species that may be common include Mormon tea, emory globe mallow, and three-awn grass.

Wildlifc: In general, the overall wildlife diversity is relatively low for this portion of YFG. Big game iitilimtiiiii is also very limited but mule deer will utilize the various vegetated drainages, particularly tIi(i~vlying cast of the area. There are no permanent natural or artificial water sources existing within or near thc Main Post site for wildlife to use on a year-round basis. Some species that would potentially occur in this area include the Arizona pocket mouse, desert pocket mouse, and Memam's kangaroo rat. Kit (ox would also be expected to occur in this area as would coyote. Bird species that may be found iiwlidc Llic hliick-throated sparrow, black-tailed gnatcatcher, western meadowlark, and the cactus wren. I(i,ljlililiti species occur in relatively higher diversities for the creosote-hursage association.

\IN,( IC's ol Concern: The only documented species of concern occurring in this area is the spiny sand \I~III~;~%(1il.M sensitive). This is a herbaceous annual that is found in sandy desert soils and has been ~I)M*IvL~on YI'C at the Main Administrative Area and the Mobility Test Area.

3 - 105 Y.3.2 AIR QUALITY

111 Yutiiii (hinty, air quality data are colllrttd by the Arizona Dcpartnient of Health Services. The c.Iosc*sl,iir inonitoring station to the YPG is located in the City of Yuma, about 30 miles from YPG. The hilion is now operated by the Arizona Department of Environmental Quality and offers.continuous -. iioiicl ispcrsive infrared collwtion for carbon monoxide, continuous ultraviolet absorption For oxidants tinil high volume sampler for particulate matter. There is, therefore, a minimum of data collection and siiialysisof air.quality data in the YPG area which would be of benefit to the installation proper. Since thm. is no active air quality monitoring station at the base, the City of Yuma air station represents the Lx.st source of ambient air quality data. The environment surrounding the nionitoring station is unlike ~- the hrgc expanse of area at WG. Additionally, it is located a considerable distance from the iiist;ill,ilion. As such, gaseous pollutant data are not truly representative of YPC proper. The particulate - (Lih, Iiowcwr, are considered at least potentially valid as the surrounding desert environment is the

1ii;iiii prkulate contributor to both the City of Yuma and YPG. Table Y.3.2-1 presents the air quality d.11.i Icir the City of Yuma and its surrounding area from 1982 through 1989.

I(xtensive monitoring for carbon monoxide at two sites in Yuma suggests that there are no significant problenis with this pollutant. Accordingly, CO monitoring was discontinued in 1985. On the other hand, ozone concentrations have been found to approach the level of the standard. In regard to particulate matter, Arizona Department of Environmental Quality has operated four monitoring sites throughout Yuma for particulate matter (10 microns or less), referred to as PMlO. Data show that PM concentrations do not vary significantly from site to site. In addition to measuring mass concentrations, simples have been chemically analyzed to characterize the sources of PMlO. This is required in order to develop control strategies for PMlO because Yuma has been identified by USEPA and the State as iroiicximpliant with the standards. Preliminary analysis shows that unpaved roads and agricultural . ,iclivities arc the major sources of PMlO in Yuma and that an 18 percent reduction in emissions is rtqiiircd to meet these standards.

With respect to emission sources located at YPG, an air quality study was performed for YPG by IW' linvironmental Management, Inc. in March 1989. This study identified various emission sources Ic~~.,ihdoil-base. These include:

lliiildinj; 2060, Petroleum Laboratory, Spectrograph Room lluilding 2500, Soils & Propellent Laboratories Ihiilciiiig 2102, Photo Processing & Graphics Laboratories Iliiilding 3490, Tracked Vehicle Maintenance Facility Sm,rll Arms Room Ihuldin~204, Fleet Vehicle Maintenance Facility

3 - 106 'I',1ble Y.3.2-1. Air quality data from the Yuma air monitoring station for 1982 through 1989.

( 'imlatninant 1982 1983 1984 1985 1986 1987 1988 1989 ozune (0,) I lighest Concentration (ppm) 0.10 0.11 0.11 0.11 0.10 0.11 0.09 0.12 (Stiinclard = 0.12 ppm within ;I t -hour period)

C',irbon Monoxide (CO) I 1ii;licst Concentration (pprn) 4.0 4.0 5.0 4.0 ND' ND ND ND (Skindard = 9 ppm within .I 8-hour period)

'l'iikil Suspended Particulates (7") t Iighest Concentration (ug/m3) 322 347 571 774 218 571 Nd ND (Standard = 260 ug/rn3 within ,I 24-hour period)

I'M IO I'nrticulates (TSP) I ligliest Concentration (ug/m3) ND ND ND 81 112 187 1543 96 (Standard = 150 ug/m3 within I\ 2~l-liourperiod)

' <:Omonitoring was discontinued in 1985. "1'51' sampling was discontinued in 1987. ' I lighcst value of three separate stations. ' I.;ibciratory analysis is not completed. Source: Arizona Department of Environmental Quality August 20, 1990.

3 - 107

- __ __ .. __ . ~ .- ...... I_-. - Iliiilding 2075, Welding Shop - Ihiiltiing 3125, I(lcrlronics Shop

Ail~liti~r~i~illy,ibxhaiisl iwissions are produccvl from a boiler located in 13uilding 506. A boiler stack .iii.iIyzis iz ntrl rtquirid unlw! usid oil is burned as fuel. This analysis would hiive to be performed ,- ~lutiii):LIit- winter months when the boiler is operating at full capacity. 'fable Y.3.2-2 summarizes the iii.ijoi- types of emissions as calculated by PRC, Inc. for each of the referenced buildings. Other sources iif owsite emissions include exhaust from automobiles, trucks and tracked vehicles, emissions from the - viirioiis ordinances and dust as a result of field operations. Exhaust emissions are also generated from ~~inpl~iywscommuting to and from the base from the local towns. Assuming a worst case, 2,144 - personnel work at YPC during normal operations. Approximately 300 of these personnel are stationed on-lusc. This leaves 1,844 personnel to commute with an average one-way trip of 24 miles. Presented IK~OWare the 1990 composite emissions for automotive traffic as predicted in the Air Quality Handbook - ciislrilwlcd by the South Coast Air Quality Management District:

Spd= 55 miles/hour ('arhon monoxide = 4.21 grams/mile Ikwtive organic gasses = 0.36 grams/mile Nitrogen oxides = 1.72 grams/mile I'articulate matter (includes exhaust and tire wear) = 0.308 gramdmile

lk~scdupon 1,844 vehicles traveling 48 miles per day, the following emission factors are predicted: ~-

e C.rrbon monoxide = 169 pounds/day Iknctive organic gasses = 14 pounddday Nitrogen oxides = 69 pounds/day I'.irliculate matter = 12 pounds/day

Wlicii firings or burnings take place in enclosed facilities at YPG, there is a one-way scrubber which is uhtd I~Irrniove potential emissions. No emissions data are available for these facilities, however, YPG - l)(iz~(~w~stlw capability of tracing specific elements. Beryllium is tracked on occasion, however, no r~~~;iil,ir(iir qiiality monitoring program is in-placeat this time. Air quality niralysis is conducted on an cd(wi(wL spt.cific and as-necded basis. ~-

3 - 108

. 'I'iilileY.3.2-2. Estimated emissions from major activities at YPG,

Carbon Sulfur Nitrogen Hydro- Particulate ()pt-rrl lion Monoxide Dioxide Oxide carbons Matter

Iluilding 2060 N/D' N/D N/D N/D N/D Uuilding 2500 0.12 kg/yr 3.6 kg/yr 0.48 kg/yr N/A2 N/A Uuiiding 2102 N/A N/A N/A N/A N/A Building 3490 350glday N/A 440 g/day 172.8 g/day N/A Building 204 683.4 g/day N/A 247.2 g/day 108g/day N/A Building 2075 N/A N/A N/A N/A N/A lluilding 3125 N/A N/A N/A N/A N/A

' N/D - No data given. ' N/A - Emission factor not available.

3-109 Y.3.3 NOISE FACTOKS

'I'lic major noise producing activities at YPG include weapons testing and vehicle noise. Weapons Ivsling noisc is centered at both the Kofa and Cibola Ranges. Both firing ranges are located from 6 to 12 niilrs Irom the Main Administrative Area so the noise generated is minimized in terms of housing loccitioiis. Vehicle noise is produced in the Main Administrative Area as well as the Mobility Test Area. .. Nois<,prociuccd in the Mobility Test Area is also too far from sensitive receptors to be considered a prdilcm. 'l'lie existing Castle Dome Heliport, located over 12 miles away from the Main Administrative - housing area, is also a source of noise. Helicopter usage is approximately 700 hours per year of which .iboul 55 percent is spent in test support. The other 45 percent of helicopter time is typically spent in training exercises. The helipad is located in a relatively undeveloped area so noise from its operation is not considered a problem.

An Installation Compatible Use Zone (ICUZ) study performed for the base has shown no .' inconipatibilities between noise zones, on-installation activities and off-installation land use or conimuiiitics. The purpose of this study was to: identify noise sources and to provide noise contours, hy Army established procedures, and a noise zone map; establish compatible land use and development oii- and off-installation in compliance with the noise zone map; identify problems of incompatibility should they exist; identify actions, where necessary, to mitigate incompatibility; and proceed with tb. - K:U% process following Army policy (reduction of noise impacts; evaluation of alternative actio. nqotiation of agreements; and implementation of agreements by Memorandum of Agreement [MOA] or ollicr means). The results of this study indicated the following:

M'ijor noise producing activities are associated primarily with the large caliber weapons operations in the Kofa and Cibola Ranges. The remote location of both ranges for on-installation personnel activities has resulted in no noise impacts within the installation proper.

Noise contour maps, prepared by AEHA using established BNOISE simulations, show no off- installation incompatibilities except for a minor excursion of Zone I1 and I11 contours into a reniote part of the Kofa National Wildlife Refuge. This is addressed below.

There are five extremely small communities near the border of YPG. The nearest large city, Yum.i, is located approximately 24 miles southwest of YPC. Yunia has aboiit 55,000 people. Any potenti'il incompatibilities have been mitigated through zoning and tliroilgh distancc from tlic noise source. Nevertheless, YPC maintains an ongoing ICUZ progr'ini to assure continued iiiiiii~iiimlionof noise impacts on- and off-base. .

3 - 110 'I'lw I)c~xirtnicnlof thc Army and Secretary of Interior establishcd a MOA in the 1950s that allows

IISI. of 171,000 acres of Kofa National Wildlife Refuge airspace for overfiring and other uses. Under this MOA and with additionill correspondence with the Game Refuge Manager, no problems with noise prvscmtly exist (Vandcr Zyl, personal communication 1990).

With rcgiird to existing traffic produced noise, noise levels for on-base roads were generated using the I:ederal Highway Traffic Noise Model (FHWA-RD-77-108) as updated with the most recently

~ .. avnilahle California truck noise emissions data (Calveno-85) for current traffic levels. The model ciilciiliitc*s the Lq noise level for a particular reference set of input conditions, and makes a series of ndjustincnts for site-specific traffic volumes and mixes, distances, speeds and noise bamers (see also Scrtion J.0.3). Though no data are presented as to vehicle usage, a worst possible case scenario was used io generate vehicular traffic noise on the major paved roads (Laguna and Barranca Roads and lst,

.~ 2nd and 5th Streets). In this "worst case" analysis it was assumed that all of the 2,144 employees and wtitraciors drove their vehicles down any one stretch of road in a 1-hour pcriod at an average speed 01 25 mph. Dependents of on-site personnel were not utilized in this simulation. Additionally, no .~ I~eavytrucks, tanks, etc. were used in this analysis. The FHWA Highway Traffic Noise Prediction Modcl predicts a Leq of 63 dBA as measured 50 feet from the centerline of the near lane for this set of cmditions. Again, this is a gross overestimate but shows that even under these extreme conditions, scmsitivc rcccptors located on-base are not currently exposed to vehicular noise above accepted levels.

- -- Y.3.4 tIUMAN ENVIRONMENT

Y.3.4.1 Visual and Aesthetic Qualities

'l'ht! YI'G is located within a sparsely populated area characterized by large sweeping alluvial fans iind riig1;cd mountains. The areas is sparsely vegetated and the hills are alluvial fans are generally in toric,s IJf brown intersperscxi with some areas of green especially within the fall months after summer rains. lhcilities are generally limited to the Southwestern portion of the proving ground. This area gcvicmlly 1i;is one and two story buildings plus numerous access roads, utility structures and test faciiitics. Many portions of this area have had vegetation removed due lo construction of facilities and ~. vCirioustwts. The remainder of the proving ground is primarily natural with some areas disturbed by vliriotis h-stin); cictivities. Some roadways, utility lines and disturbcd arcas are found through out the

KciLi I

_'' 'IC Ihiy .

3- 111 Y.3.4.2 Native American Values

‘l’liecthnic significance of cultural remains on the Yuma Proving Ground (YPG) may be based on Mor‘itto’s (1975:5)definition which states significance as “religious, mythological, social, or other special itiqxwtiincc for a discrete population.“ The determination of ethnic significance requires consultation -- willi meinhers or descendants of the group or groups which occupied the sites, or of groups that currcwtly live near the site or location in question. When discussing the values of Native Americans - iieiir YI’G, the Cocopah, Yuma, and Colorado River Indian reservations were considered. Sites which tiiiiy Iirovc’ lo be significant after discussion with representatives of these Indian groups could include ~irchwlogicalsites, burial sites (although none are recorded on YI’G), trails and trail shrines, rock art, .- intaglios (geoglyphs), and mythically associated locations. Other concerns could be expressed about c~iiciiiligcrwiplant or plants traditionally used for medicinal or ceremonial purposes and animal species - iis we4 as inorganic resources such as pottery clay.

Y.3.4.3 Archeological/Cultural/Historical Resources

Y.3.4.3.1 Cultural History

I loffnian (1984) presents a concise prehistoric and historic overview of the YPG area in A Cultural Kmoirrccs Overview and Manugement Plan for the Yuma Proving Ground prepared under contract with tb- United States Department of the Interior, National Park Service for the Department of Army. Th. dt~uintmtwas the first step in fulfillment of compliance with Army Regulation 420-40. This overview \t*ivtd ‘15 the main source for the following discussion.

I’rehistoric Resources

‘l’herrgional cultural environment of the YPG extends to 11,000 BC or possibly earlier. The Malpais ptrriod (Rogers 1939) generally refers to the oldest material found along the lower Colorado River. Dates for this pre-Paleolndian phase are reported as early as 30,OOO to 40,000 BC by Hayden (1976). Although much debated as to its temporal assignment (pre-Paleolndian or Paleolndian, San Dieguito complex), th*carliest dates generally accepted are 11,OOO to 10,000 BC (Effland and Green 1983). Representative silt’s iirc gcncrally small camps and isolated lithic scatters. The camps are often linked by trails. M,iIpis complex is often defined by stone and shell assemblages and cultural features including sk~*1iiii~;rirdes, trails, trail shrines, and geometric intaglios. The stone assemblage includes a chopper-

bu,ipt’i intiuslry often formed from basalt (Hoffman 1984). Malpnis remains have been found in all liortioiis ~IIsouthwestern Arizona and are known from northern Mexico lo southern Utah and from the C’611iioriii,idcwrts to thc Tucson Basin area. .

3 - 112 'l'lic I'cilctilndian period is generally thought to extend from 10,000 to 6,000 BC.and consists of three l)lilis(.s of Ihc Siin I)icvguito complex. Subsistence was based on a system of seasonal gathering and Iiiiiiliiil: of intrliiiin to largc game, similar to the earlier Malpais complex. The lithic assemblage is

~.li~ii.~i~~t~~ri~~~~lby crudely shaptd unifacial and bifacial tools. Other important aspects of this period itic4iicii%Irails (common along the terraces on the east side of the Colorado River valley), trail shrines, liiiil iiihElios (Rogers 1966). Evidence has extended the San Dieguito complex into Baja California, parts of iiorthcrn Sonora, southern Arizona, southeastern California, central Nevada, portions of north-central C ';I I i fornia, and extreme southwestern New Mexico.

'I'Iic Archaic period is marked by an increase in the gathering of plant foods and an empkisis on the hunting of smaller game. This period has been subdivided into three phases, Amargosa 1,II, and I I I J nd spins from 6,000 BC to 200 BC (Rogers 1958). There seem to be an increase of groundstone tools during this period. The lithic assemblage consists of corner-notched, triangular, and serrated projectile points and a greater variety of scraping and chopping tools than in the earlier Paleolndian period. Plain brownware ceramics appear towards the end of this period.

'I IN. I'iltayan period is the prolific cultural manifestation in southwestern Arizona (Hoffman 1984).

'I il(, l'iiliiyan ptrriod has been divided into three periods and extends from 200 BC to the AD 18W. The ~4citxmtimof the lithic assemblage, hunting and gathering augmentcd by seasonal agriculture along thc (:oloriido and Gila Rivers (floodwater farming), and ceramics mark the Patayan period. Multiple ixmniic types mark this period. Early types of the Patayan include Colorado Beige, Colorado Red-on- bcigL,, Colorado RL~,Black Mesa Buff, and Black Mesa Red-on-buff. Colorado Buff and Colorado Red- oii-biiff are the marker ceramics of the later Patayan 111 phase (Hoffman 1984). Patayan culture was influenced by an influx of Yuman population from southern California (AD 800) and by Shoshonean groups (AI) 1500s) who also came into the Colorado River valley from the west.

'Iherc are a variety of natural resources on and near the YPG which may have been exploited prehistorically. Bands of green and yellow clay are exposed along the terraces of the Colorado River nc'iir Parker on the Colorado River Indian Reservation (Ross 1923) may have been used in early ceramic iiiatiufacLuring in the area. The floors of the interior valleys and along the Gila and Colorado Rivers ]ii<~vitl(d);ravels for the manufacturing of lithic tools as well as grinding implements. Phyllite and

:.( IiLt foriiicitiuns prcwnt in the Dome Rock Mountains may have provided raw material for tabular knivc,s (I lollnun 1984). Andesite and basalt formations extensive in the mountain ranges north of the (Ai liivcr dso presents a significant potential resource for groundstone technology.

Aiiotlwr importmt natural resource for prehistoric populations is the availability of water. The C'tiIor

3 - 113 I'rrhaps one of the most significant source of water other than the rivers are the naturally formed rock ~~ivitiesknown as rock tanks (Bryan 1922). These tanks served as an important source of surface wa '15 well as gathering locales for game.

Protohistoric

Six ethnohistoric regional Native American groups from two language families, the Hokan and Uto- Aztecan, are relevant to the YPG (Hoffman 1984). Within the Hokan language family are the Yuman -' subgroups, the Quechan (Yuman), the Mojave, the Cocopa, and the Western Yavapai. Two other subgroups historically existed within the periphery of the YPG, the Shoshonean subgroup (Chemehuevi, mainly in California) and the Piman subgroup (Sand Papago).

These groups, at the time of Euro-American contact, had little political organization. There were no - rigid boundaries and no formal tribal banding above the community level. Environmental conditions such as the changing course of the Colorado River, the periodic marginal environment of the region, and ephemeral water sources (Le., Salton Trough and Mojave Sink) greatly influenced the population of the area. Much of this information is summarized in Mduire and Schiffer (1982).

The River Yuman (1800s-1900s), which include the Quechan, the Mojave and the Cocopa were seasonal inhabitants of the area spending spring and summer cultivating crops along the Colorado River floodplain and the fall and winter supplementing their produce by hunting and gathering along the ba of mountain ranges. Ramada structures were constructed as well as large pithouses. Caves were also occupied at this time. Ethnographic studies relevant to these groups have been done by Forde 1931; - Kroeber 1925 (Quechan and Mojave groups) and Gifford 1933; Spier 1933; Kelley 1977 (Cocopa).

The Western Yavapai (1540-1800s) also seasonally occupied settlements with spring and summer being spent along the Colorado River and fall and winter moving to Moon and Castle Dome Mountains. klistorically, the Yavapai occupied the area north of the Gila River and east of the Colorado River and are niost relevant to the YEarea. This group was typically more nomadic than the River Yuman. Subsistence was based primarily on hunting and gathering and on agriculture. Agave was also exploited by the Western Yavapai. Schroeder (1974A255) proposes that the western portion of the YPG was used by the Yavapai for the collection of agave. The remains of the Hakawhatapa, or "red-water people" are most likely to exist on YPG (Hoffman 1984). Gifford (1936), Schroeder (1974A), and Thomas .. (1974) have conducted studies on the Yavapai.

1;ton) the Uto-Aztecan language family, two subgroups, the Sand Papago and Chemeheuvi occupied m.is surrounding WG. The Sand Papago inhabited the area south of the Gila River and the CIwincheuvi occasionally crossed the Colorado River but primarily occupied the Chemehuevi Valley

3 - 114 in (',iliforni;i. The Sand I'apago have been divided into two groups, the Areneno and the Pinacateno (I I.iydc~n'1'167). The Areneno occupied the southern Arizona area closest to the YPG. Both groups led

'I ii

I listriric

'l'lic, Spanish first began exploration of the lower Colorado River and Gila River in the 1500s and continiicd iictivity in the area until after Mexican independence from Spain in 1822. No permanent sc*ttkwcnts were establishd in present Arizona. Expeditions were led by explorers and Jesuit n~i.ssioriaries, later replaced by Franciscan priests. Mexican independence from Spain brought cxpcditions into Arizona. Hunting, gathering, trapping and raiding brought Mexicans to the area ,iroiiiid the Colorado and Gila Rivers although no permanent settlements were established. Mexican jaunts into Arizona began in the 1820s and lasted until the 185Os, after the United States through the (;adsden Purchase acquired the property both north and south of the Gila River.

With the acquisition of the Arizona Territory, the Forty-Niners entered the Southwest. Historically, th-,ir(*ii of thc YPC has been targeted for extensive prospecting, with deposits of gold, silver, copper, I(d, zinc, mercury, iron, and manganese being mined (Hoffman 1984). Cold ore was mined extensively from the Kofa and Little Harquahala mountains, silver and lead mined from the Castle Dome Mountains iis well as fluorite and gypsum (Ross 1923). Fort Yuma was established the year gold was discovered in Ciilifurnia (1849). The Fort was located on the California side on the Colorado River and provided shelter and safety for prospectors and travelers. The beginning of mining in the area brought Americans to tlic areii for the first time. Towns and camps such as Gila City and Oroville sprung up with the inllux of prospectors in the 1860s and fluctuated with the success or failure of gold mines. A total of 24 mine and mining activity locales have been located on YPG but as yet only one has been recorded. 1.ittlc~evidence remains of early Euro-American occupation. Numerous old stage and freight trails do crisscross the area (Hermann Zillgens Associates 1983). Mining continued into the mid-twentieth wntury, by that time most mines were depleted or forced to shut down by a decrease in the market viiluc of nietal. Towns associated with the mining industry were abandoned or destroyed by flooding, v,ind,ilisni, or natural deterioration (Higginbotham and Associates 1978). After the mining operations virtii,illy ceased, ranching and agriculture became the principal economy of the area but never quite c.xtcwdcrl into the area of YIC due to the scarcity of water and the harsh Imdscape.

I lit%cirt~c~ of the YI'G was little utilized prior to its use by the Unittul Stales Army in 1942 as a desert trZiiiiiq; c.cmtisr. Lmd was acquired close to the testing sites from the Bureau of Reclamation and the Yumi 'l'cst Ilranch began operation in 1943 at Imperial Dam. This Test Branch was officially closed in IOW

3- 115 instiilliition was reactivated and designated as the Yuma Test Station. The Test Station was used for iIc*sc.rt ianvironmental testing. In 1957, permanent facilities were constructed which include more th; 20(1 iii'w Iioiising units, administrative buildings, and recreational facilities. In 1963, after reassignment to thcr United Slates AMC, the facility's name was changed to YPC. Testing at the facility expanded to inc,ludo aircraft, vehicles, and weapons. Presently, YPG plans, conducts, and reports on the testing of milititry munitions, weapons, mobility equipment, and aircraft and is the only general-purpose proving groiind located in a desert environment.

Y.3.4.3.2 I'revious Research

'I'hc earliest reports of archeological remains along the Colorado and Gila rivers were the results of American travelers and explorers. These early reports came from Emory (1848),Sitgreaves (1853,Blake (1x57). and carly photographs from Edward Curtis (1907). In the 1920s, Frank Midvale conducted extrnsivc survey work in southwestern Arizona to set the boundaries of the "Red-on-buff' ceramic culture (later termed Hohokam). The results from Midvale's studies comprisd the first serious ~irrlrcwlogicalstudies of southwestern Arizona and established basic cultural divisions that are still used t(K1.Iy (McCuire and Schiffer 1982).

Some of the most extensive survey work in the region has been conducted by Malcolm Rogers from 191'1 to llie 1960s. Rogers was the first to address chronology and issues of culture history in the area (I lullinan 1984). His focus in the yM3 area concentrated on the White Tank Site complex, situatc within the Tank Mountains of the East Arm Management Unit, and other cultural resources associated with tanks, major washes, and trail systems (Schaefer 1989). Another early study was conducted by Willi.im Schroeder (1952)who presented an overview of the western side of the North Cibola Range. No specific sites were identified within the YPG boundaries during this reconnaissance of the Lower Color.ido Kivcr (Schroeder 1952). McGuire and Schiffer (1982) addressed environment issues, ethtiography, and the history of archeological research in a useful and comprehensive volume which ~~ncomp~ss~dsouthwestern Arizona. Hoffman (1984) prepared a cultural resources overview and nian.igement plan for the YPG which synthesized previous cultural resources investigations, number .itid types of recorded sites, and regional cultural history.

Systematic archeological surveys within the YPG boundaries increased with cultural resource tii;in;i~cincntlegislation and Federally funded projects. The scope of work within YPC changed in the carly IY7Os and 15 archeological surveys have been conducted since that time. Prior to the 1970s, only I

3 - 116 i

Ait.liLd)gic~ilresources have been recorded throughout YPC. The majority of the recorded sites occur in thc West Arm (North and South Cibola Ranges) and in the East Arm region. The majority of iirciicwlogical surveys have been conducted in the West Arm region. This is primarily due to dcvc~le)pnicntrequirements by YPG (USACE-LA and MBA 1987). Sites have been reported in all pv};r,iphic regions and on all landform types except in active washes (Mann 1983). No official . dctc*rniiii,ition has been made on the significance of any sites within YPG. Contractors’ ri~rommeridntionsare not recognized as official eligibility statements by YPG however, they are prokvtcd iis if they are eligible pending formal determination (Nowak 1990, personal communications). As (11 1989 155 sites on YPG have been recommended as eligible for the National Register of Historic I’l.~cc~sby archeological professionals under contract.

As of I984,44 sites had been recorded in the East Arm region of YPC. These sites were primarily rccoiticii during a non-systematic survey conducted by Mann in 1982 and 1983 during a Bureau of Land M,in.i);ciiicnt project. During this project, an estimated 1,280 acres (two survey blocks of approximately (A0 iicies each) were surveyed in the East Arm. The project involved a search for previous cultural rc~sc*.irc.Iistudks on the installation and a survey to test a low level predictive model for the location of sites as a means of identifying archeologically significant areas on YPG (Hoffman 1984). Eight areas throtighout YIC were surveyed, resulting in the recordation of 150 sites. These were areas of expected Iiigli sitc dcnsity and significance; no boundaries to the survey areas were defined. High density sites weie assunied to occur in areas with fine-grained volcanic rock; low habitable slopes, proximity to major washes; narrow valleys; varying slopes; desert pavement; aboriginal trails; and springs and tanks (Miinti 1983). Except for the two limited, judgmental inventory projects, no other cultural resource survvys or systematic assessments have been conducted on the East Arm of YPG. Of the 44 sites rcwrdcd during the Mann survey, temporal affiliations are: six Paleolndian, three Paleolndian through Archiic, six I’aleolndian through Patayan, one Paleolndian to historic (mining), five Archaic, three AIcli,iic to l’atayiin, one Archaic to historic (military), five Patayan, one historic (military), and 13 uiikiiowu. I’rc-historicsite types include limited activity areas, camps, trails and activity areas associated with tiaiilh, hii‘ippin~stations, quarries, and a camp/village. Historirnlly, the military and mining ~illili~itc~tisitis ‘ire prinicirily camps.

3- 117 - ()IN. of the niosl significanl silcs rcyorded on YPG is locatcd in the Easi Arm region. The Whib 'l'.iiiks Sik was first nrordcd by Malcolm Rogers in 1939. The site consists of a series of natural wat - ccikhiiit~nts(tank) formed in a white tuff formation. The site also consists of numerous rockrings, ~.lc~iiirdcircles, niorlars, cliff panels and petroglyphs, rockshelters with grinding stones, lithic and wrSiinicssciittcrs, and a quarry area. An exlensive trail system was also recorded by Rogers connecting - tlic (;ih River Valley with the Kofa Mountains. This site along with Rogers' field camp remains and ti1hc.r sites along t.he White Tanks drainage basin are currently being proposed as a National Register - district. In addition, two other proposed archeological districts, Socket Tanks and Shy Duck Tanks, are lociilcd in the East Arm region. Twenty-one sites were recommended as eligible to the National Register but no further concurrence on formal determinations have been made. Nineteen sites were - rc~commendcdas ineligible to the National Register. Data were insufficient to make a judgement on two sites and two other sites possessed sufficient data to make a determination, but no specific evaluation - was made.

Kofa I:irinr Range -

Approxiinately 3,571 acres of the KFR has been surveyed for cultural resources. Mann (1983) -- c~otitliictetian intensive review within two sample areas in the KFRarid recordcd 27 sites. This includes iiii c*stimatcdarea of 1,280 acres. Wirth Associates, Inc. conducted a sample survey in 1980 and recorded a single sitc. The survey overlaps an area more intensively surveyed on the extreme southern portiow - d il~cKI;R by Archeological Consulting Services Ltd. in 1982 (Effland and Green 1983). This survt, was performed along a 10 km long and 61 m wide right-of-way as part of the Arizona Public Service - Yiimii 500 Kv transmission line. Four sites were recorded during the survey, two just outside the YPG bouridary (not included in this study)and two within theboundary. The two within the YPG boundary wcrc' tlrc focus of a data recovery program completed by WESTEC Services, Inc. (Schilz, et. al. 1984) to - iiiiti};iite Lhe effects on construction of the transmission line. Brian F. Mooney Associates (Schaefer and ('ocik IYHH) conducted an intensive survey of 2,224 acres along the terraces and washes adjoining the - stc*opterrain around Red Bluff Mountain. This survey demonstrated that National Register eligible sites w(w found in the narrow valleys and varied terrain as suggested by the predictive model constructed by Mii~iii(1983). A small, 247 acre, survey was conducted on the OBOD ordnance disposal area north - id Itit* Muggins Mountains by the Brian F. Mooney Associates in 1988 (%haefeT and Cook 1988). Four silc-s wtw recordid in an open terracearea devoid of major washes. None of the four sites were cligible -- for iiicliisioiis in the National Register of Historic Places as determined by the contractor.

A lot.iI of 52 sites have been recorded in the KFR. Temporal affiliations are: one Pre-Paleo to - Archiii-, six I'iileo, six Pale0 to Archaic, one Paleo-Patayan. four I'atayan, and 34 unknown. The iniljority of these sites are in the mountainous areas in the south part of the range. Site types include - ('illlrlw Iriiils and areas of associated activities, processing areas, a tank with milling feahres, quarries, - - 3 - 118 chipping stations, and rock rings. One site recorded by Schaefer and Cook (1988) was a San Dieguito pcriod cleared circle complex with a sparse and rare association of lithics and diagnostic tools. Within 1111- K1;K 'ire seven known historic sites. These sites include two historic quames, two mines, and three wt4ls (including Renner Well). Two sites were recommended as eligible to the National Register of I listorit. l'lctces by qualified professionals. Five sites were recommended as eligible by a Federal agency. 'I'wcmly-one sites have been recommended as ineligible by a Federal agency. Six sites possess iiisiilficient information to make a judgement. None of these recommendations have been formally c.oordiii,tteti with the SI-11'0 or the National Register of Historic Places. The contractol's r[,i-i)iniiicndationsfor the 18 sites recorded by the Brian F. Mooney Associates during the Rlxl Buff wrvey are unknown at this time but are suspected to contain eligible sites.

West Arm

The majority of surveys conducted on YPG are in the West Arm region. A total of 15,398 acres have bcxw surveyed resulting in the recordation of 279 historic and prehistoric sites. The large number of sites may reflect the nature of the areas where access was granted rather than a true reflection of actual site dcnsity in the overall region. Also recognized in the West Arm are 22 historic mines and areas of prospecting. An area of high research value is a water tank with possible prehistoric and historic sites. 'l'licw sites have yet to be recorded. The West Arm has been divided into four subgroups and a disciission of these follows.

Mobility Test Area: A total of six archeological sites have been recorded in the Mobility Tcst Area.

'I tit.c,c. sitc-s include the historic military encampment Camp Laguna dating to WWlI (1940s). This was riiipIi)ycd as a training camp by the troops under General George Patton. Data from this site are iiisirflicicrit to make a judgement related to its eligibility for nomination to the National Register of I listoric I'laces. Prehistoric site types include two camps, one limited activity area, one trail, and one Iiiiiikd activity area associated with a trail. Four of these sites have been informally recommended as ineli);iblc and one site, the activity area associated with a trail, has been recommended as eligible. Siirveys and overviews that have been conducted in this area include Schroeder (1952) who covered a six-iriilc stretch on each side of theColorado River; Effland and Green (1983); and Wirth Associates, Inc. (IWU). l'his area was also included in the overview by Swarthout and Drover in 1981.

Mniii Administrative Area: Several surveys and overviews have included the Main Administrative I~~eI~iiicluciing Schroeder 1952; Swarthout and Drover 1981; ansample review conducted by Mann (1982) wli~li induiks an e,timated 1,280 acres. No sites have been recordtd in this area.

North Cibola Range: A total of 148 archeological sites have been locatcd on the North Cibola ILiii1;c~. Sit(%lypes include lithic scatters, rock rings, temporary camps, and cave siles. The majorily of

3- 119 - tIit.st* sites have been recommendid by a Federal agency as not eligible for inclusion in the Nation& lh~~;ist~~rof I listoric Places. A number of surveys and overviews have been conducted in the Not .- ( ‘iluih l

South Cibola Ranve: A total of 125 sites have been recorded in the South Cibola Range. Sample - siirvrys conducted in the Range have indicated that sites may be located in varying densities throughout Iliis iireii making the number of sites actually present much higher than the number recorded. Informal - ri-conitnendations for the sites within the South Cibola Range show that many sites have been insidficiently evaluated for National Register of Historic Places status. Twelve areas of historic mines atid mining activilies have bc-n located in the South Cibola Range but have yet to be recorded. A total ’- of 11,058 acres have been surveyed or studied within the South Cibola Range. These include Schroeder (1952); Mann (1983); Farrell (1984); Swarthout and Drover (1981); Schilz and Clevenger (1985); Efflanb- cl. .)I. (1988); Effland and Schilz (1987).

.- Y.3.4.4 Zoning and Political Boundaries

YI’G has been split into five separate zones (Figure Y.3.4-1);these zones have been mapped at a scale - of 1:6O,O00. To allow a better perspective of the actual impacted locations that traverse more than one %one,YI’C has been divided into geographic regions (Figure 2.1-3). The basic mission functions that occur in Lhe specific geographic regions are as follows: -

Norlh Cibola Ranze: 1) Aircraft Armament Systems; testing includes facilities for both development -

3 - 120 .------9 I I I I i---- ZONE E i I -I I i i I I I I r--1 I I I I I I ZONE Cl ZONED i I I

'-1. I I L I 7 ZONEA I ZONE! B

0 I '? I I miles

~ - Aclniinislr.itivc Are.): Supporl Facilities and equipment. -

Mobilitv 'l'cst Area: 1) Mobility Equipment; includes the test and evaluation of wheeled and track '- hyiilt; vc4iirles. comhal vehicle weapons, target acquisition systems, components and related items (iidiiiliq; tltiik fir(- coiilrol syslvms), fuels, lubricants, and other intloinolivc chemical products; and 3 SuppotL I;iic.ililics ;itid quipment.

KOfii l:irinz Ranre: 1) Munitions and Weapons; see South Cibola Range; 2) Support Facilities and - cqiiilmiiwl; and 3) Bivouac. - Ihst Arm: 'I) Support Facilities and equipment; and 2) Bivouac.

YI'G is located in the southwest comer of Arizona in the counties of La Paz and Yuma. It is - approximntely 1,300 square miles in size, since 50 square miles of the southern portion was transferred tu Ilic US.Bureau of Land Management (BLM) in 1983, The installation is almost entirely surrounded - by public lands, either by wildlife refuges or land administered by the BLM. The Colorado and Yuma Indian Ikservations are within 100 miles of YPG. The Colorado River runs almost parallel to the wcslrrn border of YPG and is the boundary between Arizona, California, and Mexico. The Gila River -- nitis djaccnt to the southern border of YE. Luke Air Force Base is to the south, also (Figure Y.3.1-2). - -

Y.3.4.5 Socioeconomic Characteristics ~-

Y.3.4.5.1 Installation and Regional Overview - Y IY;,as are all military installations, is an integral part of the overall regional social and economic fabric. 'The study region is the counties of Yuma and La Paz in Arizona and Imperial in California, cmcciiiipnssing 14,167 square miles. La Paz County, Arizona was fornied in 1982 from the northern - portion of Yuma County. The 1980 Census count for the region's population was 182,664. It is c*stiiniiltrdthat the 1989 regional population to be 227,708, an increase of 24.7 percent. The projected - IYJ4 rcgional population is 254,320. The 1988 civilian labor force was estimated to be 99,859, with the larp-st itidustrial sector being Services with 17.8 percent of the total employed labor. The regional iiiic,iiil)l~iyii~ciilrate is 19.4 percent. Of the total regional civilian employed labor force, it is eslimattd ~- 1h110.3 pcmwt iirc cmploytd at YK. The regional yearly per capita income for 1989 was $8,894.

3 - 122 Wildlife Refuge s t~.1t c Indian Reservation

B1.M

Military Reservation

Surface Management status, 0 10 20 30 1:1,000,000, 1979 I I 1- I mi Ics

I:igurr Y.3.4-2. Generalized land ownership, YPG.

3- 123 Y.3.4.5.2 On-l'ost I'opulation - - A\ of June 15, 1990, YIY; was authorizcul to have 323 active duty military employees. It als t*iril)loys05.3 full-time civilians and 68 temporary workers and 600 to 800 contract employees for a total workforce of 1,944 lo 2,144. The base has a dependent population of 300 to 500 (Chuck Wullenjohr- pmoii.tI ~~onimunic.ition19YO), so that the total day time population ranges from 2,244 to 2,644. YW m.itii c.intonment area is located approximately 30 miles northeast of the City of Yuma, which is the- rotrnty seat and the largest city in both Yuma and La Paz Counties.

Y.3.4.5.3 Land Use -

Y I'G encompasses 838,174 acres of land in southwestern Arizona, including small amounts of leased stalc and privately owned land (Table Y.3.4-1). An additional 713 acres of off-reservation land are- availiible to YPG, these consist of 554 acres at the Blaisdell Railroad Siding Site and 57 acres of Electrical 'l'r,insinission Line. YE, also, has airspace rights over 171,000 acres of land within the Kofa National- Wildlifc Refuge. Theland useassociated with thesix geographical regions is shown in Figure 2.1-3. The lotd land under custody and accountability for Army use is approximately 1,010,000 acres (USACOE-LA - .1nd MIJA 1987).

'l'hc Cibola Range makes up the western leg of YPG and contains the West Environmental Test Arp- .itid tIi(: Castle Dome Heliport annex areas. The area is approximately 20 miles wide and 40 miles atid is best described as being coniposed of large plains surrounded by mountains. Due to its size, - isolation and natural barriers of the surrounding mountain ranges, this range was developed for aircraft arniitment testing. The Chocolate Mountain range divides the Cibola Range into the North and South Cibola Kanges. The North Cibola Range is used for static detonation, conflagration testing of - ;initnunition items, navigation system testing, and often for combat skills training and testing aircraft armament systems. It also has two laser sites, five position location system (PLS) "A' stations, and two - microwave stations. YPG also utilithe North Cibola Range for nap-of-the-earth flight testing.

'Hw South Cibola Range consists of an area 20 by 30 miles with accurate space position - ii~s~~iiitii~ritii~iongiving accuracies of 33 fwt for PLS or 3 feet using Prwision Laser 'Tracing Systcm in X,Y,% coordiniNes. It has four laser sitcs, a PLS master station with five "A' stations and one microwave - sl~tli~~ti.'I'lirre arc also five surveyed instrumented drop zones (DZ)and two extraction zones (EZ). l'iirtit4wtv pack and maintenance and rigging facilities support the testing of airdrop and testing of ~*htt*rii,iltraisport by helicopter. -

'l'lic. M,iin Administrative Area is the only region that maintains its own formal land use plan. The - ~ ~oliowiti~;is .i list and brief description of the land uses. - - 3 - 124 Tahle Y.3.4-1. Reservation land within YPC.

‘Iyp Approximate acres

Public Domain Withdrawal 829,882 State of Arizona Land (leased) 7562 I’rivately Owned Land (leased) 320 Patented Mines (privately owned, not leased) -410 Tot’ll 838,174

Source: USACE-LA and MBA (198F124)

3 - 125 - liiiiiily I Ioiisiiig (0111,.cr/NoncomrnissionldOfficer (NCO) - A total of 287 housing units t1 coinlirise approxima.dy 50 percent of the developed region. 'I'roop llousing . Located in one area and consists of one large permanent barracks, having a ):n)ss capacity of 436 spaces. - Officer Housing (BOQ) - This consists of a single wing BOQ building with 30 units available and is locatcd in the southcentral portion of the main administrative area. - Community Facility - There are six of these facilities: a guest Irouse; the Post Chapel; Post Nursery School; a building that contains the Education Center, Credit Union and Thrift Shop, I'ost Exchange, snack Bar, Library and Community Club; US. Post Office; and - l+unily/Community Service Center. . Service - These are scattered throughout the area and mainly consist of utilities, engineering, - maintenance, storage, and administrative services. Ibxeation - These facilities are located at various locations throughout the area. School - This is the Post Elementary School - Mdical - The three facilities consist of the YPG Health Clinic, the Post Dental Clinic, and a Veterinary Clinic. - . Security - These land uses consist of a sentry station and administrative facilities at the nlain cnlrance, an emergency operationscenter, and a Provost Marshal Investigation Evidence Storage Iluilding. --

The Mobility Test Area focal point is the installation Branch Headquarters. It has the responsibility - of planning, implementing, conducting and submitting reports on the testing of automotive and mobil material including tracked and wheeled vehicles and general equipment assigned to YPG. Numerous tests of automotive typeequipment including combat vehicle weapons systems, general purpose, special - and tactical vehicles, industrial and power generation equipment, construction equipment, missile ground support and fuel distribution system equipment, automotive components and materials and - military fuels and lubricants have been conducted at YPG. The YPG facilities are capable of performing nearly all typw of field performance and controlled engineering tests.

'I'liv Kof;i 1:iring Range is approximately 5 miles wide and provides range to 40 miles for dircrt and iiitlirttl liro weapons. 1.triilcd on this rangeare observation towers and biinkers, prepnred impact field .- ;it vorioiis ranges, and surveyed gun positions along the northwest and south boundaries. This range is tlrc' focal point of tube artillery testing at WG. Range instrumentation includes high speed cameras, i-iidiir, riidar velocimetcrs, flash x-ray, tracking cameras, sky screen, fuze chronographs and height of - Iiursl vide-o monitoring equipment. Supporting facilities include ammunition preparation and storage, tempc.rahirc condition boxes and environmental simulation facilities such as rough handling, ~- lr~iiis~i[)it;ilioiivibration, drop towers, temperature/altitude, temperature, humidity, enveloping flame, -

3 - 126 titist ,III~s,ill log rli,iiiibcrs necessary lo perform ammunition safety tesls. 'l'liere are approximately 150 \lt*vt*lt)pcdaiid undeveloped impact areas and 300 firing points located on this range. The restricted ,iirsp.iw area covers the artillery firing range of the KFR, and has a surface to unlimited ceiling range.

'l'tir li,ist Arm runs approximately 18 miles north-south and 6 miles east-west and is a portion of the Kd,i 1;iring Kangc reservtxl for ground and air to ground firing programs. It is relatively undeveloped vxrcpl lor occasional single lane roads and tracks and trails passable only by four wheeled drive veliicles. Table Y.3.4-2 shows the acreages of the various categories. These land uses exist on 872,666 'icrc's ol the tola1 on-reservation and off-reservation land currently available lo the Army.

l;i~;urc~Y.3.4-3 sliows the ceiling ranges for all of the restricted airspace Lhnt currently exists.

'l'hc installation commander has the responsibility for three categories of ground land use on a inilitary installation, these are; improved, semi-improved, and unimproved land.

Imprcived grounds include land on which intensive maintenance activities are planned and performed annually as a fixed requirement. Semi-Improved grounds are areas on which periodic maintenance is performed but to a lesser extent than on improved lands. Unimproved grounds include lands upon which maintenance does not occur on a regular basis.

.II here ,>reno commercial forest stands on YPG nor are there any agricultural outleases. Outleases are iiot considered a viable alternative in the future either because 1) grazing, while being a good iii~ii~~i~;~~~iic~iLalternative, is prohibited because of the danger involved with unspent munitions from w~'~I~)III~~,.ind lack of forage and water, and 2) cropland leases are impractical because of the expense

111 irripilions and the expense of mitigating for impacts from testing operations.

Y.3.4.5.4 Kegional Economic Activity

YIY; is Iorattuf within La Paz and Yuma Counties, Arizona. The County of Imperial, California is Io<.ottd to tlic west of the facility. The regional economic analysis for the proposed action was oriented to Yuiiia 'ind Imperial Counties for several factors. The primary factor centers around the location of thc, in,iin pust area to the various towns in the area. Yuma is the closest population center and is where most off-post employees live and where most on-post personnel purchase goods and services. Imperial ('outity (principally the City of El Centro) would be the next likely place for expenditures for goods and scwit-t,s.I ..I I'iix County is ptimarily agricultural based (population 5,000) and has few centers for sales (if };(iotis,ind scrvices. Additionally, the transportation network for the area is such that. people living or workin}; .it YI'C; would not travel to La Paz County on a frequent basis.

3- 127 . otii <.t:: Wigginbotham and Associates, 1978

i'igiirc Y.3.4-3. Existing rcslTicled airspace, nC - 3 - 128 '1,ihle Y.3.4-2. Land use.

Acres

IMI'ItOVED LAND AREA l.iwns (Facility Engr.) 28.45 Lawns maintained by others 41.0 Alhletic Fields 5.4 Golf courses 0.0 I'arade and Drill 8.1 I'ost Cemeteries 0.0 I'lnygrounds and Parks 9.48 Other 40.57 'I'UIAL 133.0

SEMI-IMYROVED LAND AREA Airfields 77.0 IhpZone 2,084.0 I

'ICO'fAI. 3375.0

UNIMPROVED LAND AREA Animunition Storage 1 .o 'l'iwporary Use Land 2,541.1 In I.ease Land 8,452.0 I'avements and Railroad 534.0 Ihilding Structures 26.0 'l'c*st Areas 857,604.0

KYIAL 869,158.0

Sotwe: I ligginbotham and Assoc. (1979)

3 - 129

- - 'l'hccounties of Yuma and Imperial have an estimated 1989 population of 227,708 with Yuma Cour - .ic'counting for 91,400 of this total population. The area is rapidly growing and has grown by Qipproximately24 percent since the 1980 census. The area has komea haven for retires and the winter population is considerably higher than this figure. -

lkiployment in the area was estimated at nearly 100,000 in 1988. Employment by sectors is provided in Table Y.3.4-3 for 1987. Government employment represented approximately 20 percent of this cniploytnent figure with Yuma Proving Ground representing approximately 0.3 percent of total c~mploynicnt. Unemployment within the area is quite high and was recorded at 19.4 percent in 1988. - IJtic.iriploymetit is much higher in the summer months when agricultural operations slow down and - tiniriwi is virtually nonexistent due to the high temperatures. . 'l'hc 1989 per capita income for the two county area was $8,894 with total household income near $27,000. Total personal income for the two county area was $2,444.3 million in 1989. - Y.3.4.5.5 Housing - On-Post Housing

- \ YIT; currently has a total of 287 housing units including 79 officers quarters and 208 enlist quarlcrs (Mark Smith, personnel communication, 1989). Currently 270 units are rented with a total ot 22 units occupied by civilian personnel and their dependents. The post has developed a priority for '. assigning available housing with Army personnel having first priority, Marine personnel having second priority and civilian personnel having third priority. Civilian personnel with a Government Service - riititii; of 7 or above arc assigned officers quarters and those with lower ratings are assigned enlisted lioitsiii~;. - C)ff-l'ost Housing - 'l'lic.rc ;ire ;in cstimatcd 73,000 housing units within the two county area. The vacancy rate is cstimiitcd at approximately 8 percent. The average price of a home within the Yuma area is around $hS,OOO. The availability of winter rental units is frequently tight due to the large influx of winter - visitors.

3-130 'I'.ihle Y.3.4-3. Total full-time and part-time employment.

Iiidiislry 1987

Total Employment 93,918 Wage and Salary Employment 81,368 Proprietors 12,449 Farm Proprietors 1,698 Non-Farm Proprietors 10,751 Farm 9,789 Non-Farm 84,028 Private 63,410 Ag Sew., For., Fish., and Other 12,697 Mining 61 1 Construction 3,977 Manufacturing 3,463 Transportation and Public Utilities 2,947 Wholesale Trade 3,875 Retail Trade 14,815 Finance, Insurance, and Real Estate 4,326 Services 16,699 (;ovemment and Covt. Enterprises 20,618 Federal, Civilian 3,580 Military 4,922 State and Local 12,116 .~

Source: Bureau of Economic Analysis, Regional Economic Information System, April 1989

3 - 131 Y.0.4.5.6 Schools

<~i-l'(isISchools - 'l'liv J.inics I'rice Elementary School Provides K-5 education to on-post military and civilian tlepcndents and the surrounding community. Current enrollment is 140 military dependents and 26 .. civilian dependents. There are currently six teachers employed at the school. Secondary school students ;it YIY; attend schools in Yuma. - Off-Post Schools - Table Y.O.4-4 lists school districts near Yuma Proving Ground. This table also lists current c.nrollnient, number of dependents from YPC, and estimate PL-874 assistance. Yuma Elementary School Ihtrict No. 1 and Yuma Union High School District cames the majority of military and civilian '- &*pendents with the Crane School District No. 13 also providing education to n significant number of civilian dependents. It should be noted that no records of YPG civilian or military dependents attending - linperial County Schools could be found. Table Y.3.4-5 lists parochial/private schools and schools of 1iil;lik-r education within the YPG area. - - Y.3.4.5.7 Health Care - Mctlical facilities for base personnel on YPG consist of the YPG Health Clinic located in the Main Administrative Area. Out-patient care is provided only, as no in-patient facilities currently exist. Two military physicians and support staff can conduct routine x-ray and laboratory procedures; however, - serious illnesses or injuries are treated at the Yuma Regional Medical Center, located approximately 27 miltrs wuth of the health clinic. Emergency transportation is by ambulance (eight currently exist on YI'C) or by helicopter from Luke Air Force Base and/or Yuma Marine Corps Air Station. Transport lima from tcst areas to the YPG Health Clinic ranges from 15 to 60 minutes. Surface transport to Yuma l<~*~:ion~ilMcdiral Center takes approximately 30 minutes. Except for orthodontics and severe dental .' trdmia, all gc~nvriiland routine dentistry procedures are available at the Dental Clinic at YPC. The (.liiiic. is shfftd by two military dental officers and three military dental assistants (a dental hygienist .iii(i two civilia1i assistants). Local medical and dental services in Yuma that are available to civilian 1)c~rso1111(~1iind their dependents are included in Table Y.3.4-6.

3 - 132 'Table Y.3.4-4. Summary of characteristics of school districts potentially affected by proposed alignment.

MilitaryKivilian Tolal NO. of Dependent PL-874 Enrollment Schools Enrollment Assistance

7.Otx) 3 93 $2,886

7,965 I 13 375 $14O,ooO

4,218 5 75 $1,157

1,200 2 0 NA

310 1 0 NA

250 1 2 0

452 1 NA

193 1 NA

1,897 2 NA

I ~K'L~not inihJc jamcs Price Elementary on YPC which is part of Yuma Elementdry School District 11115 ic h101h.15 grdm K-5, an cnrollmcnt of 1%. and 6 teachers.

3 - 133 'l',iIilt- Y.O.4-5. I'rivnti. ~liciolsand univcrsitii-s whcre YPC dependents attend.

No. of - Dependents school Type of School or Personnel

SI. I(rniicis of Assisi K-8, Parochial

Yicniii Lutheran School K-8, Parochial 10 -

I niln,iculate Conception Parish K-8, Parochial 2 li Arizona Western College 2-yr Associate, 40-50 Technical

(:ocliisc College Airframe and Aviation Training 2 I'owcr Plant Training and Flight Main.

Nti. Arizona University Electrical and 7 Srht~olof T~rhnicalCareers Aviation Mgmt. --

3-134 'fable Y.3.4-6. Medical facilities at Yurna. Arizona

TY Pe Number

Hospital 1 (283 beds, including intensive care unit)

Urgent dare Unit 1

Geriatric Care/Living Facility 6

Physicians and Surgeons 102

I nternists 14

Ortldontists 4

Optotnetrists 7

Dentists 33

Family Practice 11

Psychiatrists 3

Siurce: Arizona Dept. of Commerce (1990)

A veterinary clinic is also located on-post.

3 - 135 - Y.3.4.5.H Public Safety ~- - Pire I’roteclion

l,’irt-lmiltScticin on YIY; c‘onsisls of a single fire station located at I,iiguna Army Airfield, manned by -- 34 pvrsonnel working in two shifts of 17 persons each. Major equipment includes three 53OC fire trucks, n 3/4-lon rescuequipped pickup truck, and a 988-gallon water tanker. A mini-pumper and rescue Iruck arc also available for assistance in automobile rescue operations. A twin-agent vehicle (TAV) is - avaiilablefor aircraft crash operations. Inspections of fire equipment of the OB/OD area are conducted brforc and after each operation with vehicle fire protection equipment inspected daily. Logs of - insptu.lions are kept for three years, in accordance with Arizona Department of Environmental Quality rquirements. Various Standard Operating Procedures (SOPS) also specify fire extinguisher inspection proccdures; recorded of extinguisher discharges and recharging and reissuing of extinguishers. Army - I’ublication AMC-R 385-100 specifies the model of fire extinguisher to be utilized for various types of firis Fire quipnient is on-site during aircraft munitions testing, low altitude parachute extraction, and ~ abnormal flight testing operations. Locations of stored flammable materials, ammunition, and chemicals ;ire recordrd by the YPG fire department, which is notified when ammunition is being transported. - Mtltcriill-rclatcd occupational hazards on YPG are expected to be similar to those at other military insliilliitions. The types of injuries to military personnel that could occur from military operations- - include burns, concussions, contusions, dismemberment, internal injuries, hearing and vision injurier smoke aiid dust inhalation, dermal exposure and inhalation from chemicals, pesticides, and fuels, .- inibcddd fragments and shock. Snake and insect bites may also occur during operations.

Contaminated Areas .*

As previously mentioned, a full discussion of hazardous materials on the WG site is found in - Section Y.3.4.6 of this report. Surface areas contaminated from military operations include impact areas Ihat receive UXO, some DU and beryllium, areas utilized for demilitarization of propellants and .immunilion or fuels, and areas that have been used historically as environmental (chemical) test areas williiii lhc YIY; site, shown on Figure Y.3.4-4. Virtually the entire active portion of the firing range is i~~i~iI~ii~ii~i.il~~~by UXO. UXO has built up over the years and is reniovtul by range cleanup when time - iiiid i-cwiiirc1-s permit. 1 lowever, these efforts do not assure 100% rcmoviil and achieve cleanup of the surf.icc oiily. I;or this reason the range is considered contaminated. UXO by far is the single largest [,~iiil~iIiiiii.iti~)Iiissue at YI’C,.

3 - 136 I I

!13 i I I r------1 I

miles,

Kprc Y.3.4-4.Contaminated areas on YPC.

3 - 137 Y.3.4.5.Y Traffic and Transportation

Mriins of regional transportation are summarized below and depicted in Figure Y.3.4-5.

Yunia Proving Ground lies between two major east-west highways: Interstate 10 to the north, which is tlw iiiiijor freeway between Phoenix, Arizona and Los Angeles, California; and Interstate 8 oil the soiitli, which passes through the City of Yuma and is the major freeway belween Tucson, Arizona and S;in I)iq;o, California. U.S. Highway 95 is a two-lane, asphalt-surfaced scyondary route linking San - lmis, Yum;~,Parker, and Quartzite, Arizona. It enters the YPG site at the southwest comer and runs in ii north-south direction, bisecting YPG through the North Cibola Range, South Cibola Range and

~~ Mobility Tesi Area. It connects with U.S. Highway 80 (Interstate 8) at Yuma, Arizona and US.Highway 60-70(Interstate 10) at Quartzite, Arizona.

laguna Koad is a paved turnoff to the west from Highway 95, at the "Big Guns," which passes the Mobilily Test Area and leads to the Main Administrative Area. It becomes California Highway 524 .. after crossing the Colorado River. Use of Highway 524 is increased during time of flash flooding which affects and restricts usage of Highway 95. Martinez Lake Road is another turnoff to the west from Highway 95 allowing Martinez Lake residents, and boating, fishing, and camping visitors to reach the . lakc, iiiid areas west of YPG's West Arm.

Iiitvrior roadways are located throughout the installation and are paved only in areas where they -'. s('rv(. .IS ii link between functional areas. Intrarange roadways are constructed of gravel. Most of the rciiidwi~ysand parking areas of the main operational areas have been asphalt-surfaced or paved. The - l;riivc*l road system at YPG was upgraded and resurfaced in 1982, 1983, and 1984. During these three ycurs. tlw subbase of the roads was replaced where required and, in some instances, a 6-inch road r~impiictof clay-gravel was constructed where necessary. The main arterials and well-traveled . scrcindaries arc presently maintained through contract. Continued cyclical maintenance is performed iind iiicludcs grading, watering, and repair of storm-damaged roads. Intercity bus service to and from . Yuniii is provided by the Greyhound and continental Trailways bus lines. Daily bus service is provided Iiy tlw Army between Yuma and YE. - ICaiIroacls

'I'lw niaiti cost-west line of the Southern Pacific Railroad is locntcd approximately six miles (10 hiloiii~~t(w)south of the southern boundary of the reservation. Freight transportation service to YI'G - is pi-iivitlcd hy the Southern Pacific Company. YPG has a railhead siding located at Haisdell, Arizona, - 3 - 138 I

FreewaylHighway +-i-+-+Railroad (Southern Pactftc) @ Civil Aerodrome @ Military Aerodrome @ Rolh Civil and Military Aerodrome 0 Aerodrome Stale Border

I+'igurcY.3-4-5. Regional transportation system, YPG.

3 - 139 approximately 17 miles (27.4 kilometers) south of the installation. This siding is used for both cargo and ,iininunition and is under the control of the installation through leases, licenses, and joint-1 -. q,n-tviic-nts. 'I'he railroad express office is located in the City of Yumn. Liniitcul AMTRAK passenger st*rvic.v is Imvidcul into and from the City of Yuma. Trains are avaihble to destinations east and west ~i~)~~i-~~xiiiiiit~~lyevcry other day. There are no railroad lines within the installation proper. All inbound .- ,id outbound rail freight are transported within the YPG site by Government vehicles.

i Aircraft

laguna Army Airfield (LAAF), located within the site approximately two miles (3.2 kilometers) east - of ~hcmain cantonment area, provides military air-transport support. Two runways are provided, including Runway 18-36, a 5,150 foot long, 150 foot wide main north-south runway; and Runway 6-24, - .in djacent, less usable, east-west runway of 6,000 feet (100 feet wide). The airfield was designed priiniirily for small, fixed wing and rotary wing aircraft. The north-south runway, while relatively short, IIBS Lwen uscd by US. Air Force (USAF) C-130 and C-141 transport aircraft. However, the length of the *~ ninway would be a problem for a fully loaded (2-141 which requires a minimum 6,000 feet for takeoff growid nin (TCR). The airfield complex covers approximately 723 acres (292.6 hectares) and ~- ;icclinimodates runways and required support facilities. Access to this airfield is restricted to aircraft with prior established clearance. -- I lelicopter Transportation

111 addition to Laguna Army Airfield, YPG has the Castle Dome Heliport located approximately 16 miles (25.7 kilometers) to the north-east of the main cantonment area and near US. Highway 95 (see Vigure Y.3.4-5). It provides one 3,000-foot long, 6Sfoot wide runway capable of supporting rotary wing - aircraft, either under test or in support of tests. The heliport has four aircraft parking spaces, two aprons and a dual hanger. Limited traffic control capability during daylight hours is available. A hrlicoptcr pad, to be used in emergency situations is located in the Main Administration area.

Air Access

Aircraft operations over YPC are conducted in conformance with Federal Aviation Administration - (I;AA) rq;ul;itions. Airspace restrictions are ncccssary due to artillery and aircraft armament testing. AI1 rt-strickd air spncc is properly indicated on current aeronautical charts. YPG controls the use of ri*stric.ttd airspace during work hours, however, Marine Corps Air Station, Yuma (MCAS) controls ~k wstrictcd airspace during nonwork hours. The Air Force, Navy and Marine Corps niay schedule YPC iiirsp.it.c for exercises. Any temporary release of air space is coordinatcd with other military services ~. and lo~ilFAA flight service stations. The flight service stations relay pertinent information to .-

3 - 140 ctmiiiiwcial and private nights as rquired. The airspace envelopt. over YIC and the adjacent Kofa Nlilioti.il Wildlile I

M 1111it ioiis Transportation

Munitions currently reach YPG from Amy Depots, other facilities, and contractor facilities via truck. 'l'licse lrucks are generally privately-owned vehicles operated under Department of Defense and US. ;i rni y regula tions.

Y.3.4.5.10 Wastewater Disposal

Sewage is discharged into septic tanks or specially designed evaporative lagoons. The five (5) total rckirtkiii lagoon systems at YPG are located around the Main Administrative Area, Laguna Army Airliclcl, Mobility Test Area, Kofa Range Area and Castle Dome Heliport, as indicated on Figure Y.3.4-6. Iiich sile also has domestic wells located nearby. According to the 1987 Final Environmental Asscssment (USACE-LA and MBA), the facilities appeared to be sufficient to handle the sewage prodiiced at YPG. The sewage lagoons are cleaned every three years and septic tanks are pumped on 11 regular basis. In 1983, approximately la0,OOO gallons per day of sewage were produced. YFG currently disposes of domestic sewage by land application through evaporation and infiltration ponds. Since the evaporation rate is up to 10 feet/yr much of this material evaporates. The remainder infi1tr;ites into the ground.

Y.3.4.5.11 Solid Waste Disposal

YIY; generates nonhazardous solid waste in the form of garbage and paper products. The i~istalliiticincurrently uses one permitted sanitary landfill to dispose of municipil solid wastes. All non- 1i;iz;lrJous refuse disposal is accomplished within the base boundaries. lypical processing procedures iiicli~cl~~placing each day's collection into a large, rectangular trench and covering the waste with a layer of soil. 'l'lic location of the active landfill and five other inactive sites are shown in Figure Y.3.4-6. The p(wiiilttui Iiintlfill is located north of the Laguna Army Airfield.

Y.3.4.5.12 Hecreation

'I'h*IoIIowin): discussion of rxreational facilities and opportunities on and ininiediately adjacent to YIY; w.is hkcn from the Final Environmental Assessment United States Army Yuma Provine Ground (USACI:-IA and MBA 1987). It focuses on the total number of recreational resources. instead of an iialividti.il breakdown of facilities by specific geographic location, due lo the limited availability of

3- 141 3- 142 .~ji~ilit~,ililt*~LILI. 'l'lit~priiii.iry wncrntralioii of rcvrcation resoiirccs is locnlcd cciitrally within the Main Atliiiiiiislr,itivc Arc'a, cxcepl the sel~tedhunting areas located in tlic North Cibola Range.

(hi-1'0s t Kecreation

YIY; provides several facilities for recreational activities by assigned military personnel and their fmiily members. These include an enlisted service club'that sponsors a variety of events, a skill- dcvi4tipmciit center (craftsmanship with automotive repair facility), a movie theater, various picnic I.icilitit*s, and a boat dock rental facility at the nearby Colorado River. YPC also has athletic fields; Icriiiis, haridball, and basketball courts; playgrounds; a new gymnasium; a swimming pool; and a howling center. YI'G swimming facilities consists of an Olympic-size pool with two diving boards, a kid~licpool, mid modern lockers and showers. The facility is in Building 520, located in the Main Administrative Area. Available programs and equipment include water basketball, water polo, water vtillcybnll, swimming lessons, masks, fins, and snorkels.

Ibxional Recreational Resources

Yuma and La Paz Counties' diverse physiographic characteristics, sunny climate, and natural water rc'soiirccs are ideal for outdoor recreation. The Kofa, Muggins, and Castle Dome mountains in the

... .~ northcrn part of the county, and Tinajas Altas Mountains in the southern part of Yuma County offers opportui\itics for camping, hiking, small game hunting, and rock hunting. The Gila and Colorado Rivers offer year-round water activities. The Colorado River provides fishing, swimming, rafting, and sunning.

Y.3.4.5.13 Utilities

Wtrlls arc the primary sources of water at YPG. Of the 13 wells located within the instnllation, 11 .ut.* t,iirrL*iitly in use. The 11 wells supply water to five separate water distribution systems within the YI'( ;. l

3 - 143 T'ihlr Y.3.4-7. Water supply at YPC - 1985.

Discharge Water Generated Capacity August 1985 - Geographic Area Wells (gpm) (million gal/rno)

Main Administrative Area X 980 14.2 Y 980 23.8 . - Mobility Test Area U 200 1.9

Kola Firing Range W 200 2.6 - H 170 1 J 200 0.7

Lower Cibola Range Iagurw Army Airfield B 170 1.4 I>ynamometer course I G 100 0.2 - West Environ. Test Area V 35 0.4 S 0.4 65 -- C''isIlt! Dome Heliport M 170 -0.8 Total 46.4 -

' Well Ii did not operate in August 1985 ' Nonpotable water supply for road maintenance

Source: Entech (1986)

3 - 144 W,itvr is not readily available in the northern part of the YPC; installation, specifically the North

( 'ihiLi I

t listorically, the potable water supplied to the Main Administrative Area and to housing units at YIY; has been of inadequate quality due to high levels of fluoride. YPG has had to supply the Main Adiiiiiiistrative Area and housing units with bottled water. As a result, an electrodialysis reversal (EDR) wCilcrtrriitment facility was installed at the Main Administrative Area in February 1986. The plant is dc~si~:iicdIo eliminate excess fluoride from potable water supplies. The two wells within the Main Adiniiiislrative Area supply water to the treatment plant. As a result, bottled water is no longer iiei..cs.;iry in the Main Administrative Area.

.- IInergv Consumption

lincrgy ustd at YPC consists of three types: 1) process energy, which is defined as electrical energy wiisutiied by equipment during mission operations; 2) facilities energy, which is energy consumed by briilifings (i.e., for heating, cooling, lighting, and power generation); and 3) mobility energy, which iiii.Iiidcs mobility fuels for the Aircraft Armament Branch, Air Movements Branch, and Mobility 1in):iiitwing Branch.

Energy Sources

YIY; rcccivcs electricity from three sources. The primary source (approximately 90 percent) is from

,#I hydroiktric station owned by Western Area Power Administration (WAPA) from Parker, Davis, and ( '~iloi~~itl~iI

Iilcctricily from WAPA is transmitted approximately 10 miles from a substation near Yuma (Gila Subst.ition) IO YPC via a 34.5 kva transmission line. Substation C is in the process of being rebuilt and

3 - 145 - is 95 prrctmt complete. Improvements to the substation include increasing the transformer capacity from 1,500 kva to 3.000 kva, and installing an OCR (oil circuit reclosure) protective device. T siihsliilicin transmission line (Army-owned) has a maximum capacity of .12.5 mva and, thus, could - traiisinit ii greater amount of electricity if necessary. Once the eltqtricily rcaches VPG, it is distributed Iliroiiglioiit tile installation via area substations to the following five locations: Main Administrative . Area, Mobility Test Area, Kofa Firing Range, Castle Dome Heliport, and Cibola Range.

Fuel and Heating Svstems I

YI'c's prime fuel for water and space heating is fuel oil. In a few locations, electric resistance - hc.iters are ustd but this makes up only a small portion of overall heating equipment. The fuel oil lwriicw, well-inaintaind and clear burning, along with a very short heating season, result in very little pcdlcitioii to the air. -

Conservation Programs -

(histwation programs incorporated at YPG have been successful in reducing the amount of energy c.oiwmcul. Most of these conservation methods involve improved technology and upgraded building - dtrsigii fwtiircs. Some of the methods currently utilized and proposed for WCinclude: 1) replacement of existing air conditioning units with newer, more efficient models, 2) installation of Capehart stoq~- windows, 3) installation of solar hot water heaters, 4) installation of "blown-in" and "exterior" insulatir and 5) development of a tree-planting plan to reduce energy costs under the YPG Natural Resource Management Plan, which is currently being updated. .

Y.3.4.6 I la7.ardous MaterialsMastes -

Many types of toxic and hazardous materials are used at YPG and will be addressed in this study. 'I'lii~sc~include chemicals, oils, solvents, toxic metals and fuels used in the daily operations of the various ~- t)irildinp and shops; fuels used in the operations of aircraft and vehicles; explosives and propellants iis(x1 in ordnance testing; and depleted uranium (DU)and beryllium (Be) which are used in specialized ~- prc)jtx.tilc!s. liach of these types of hazardous materials will be dealt with in the following sections.

Y.3.4.6.1 Hazardous Materials Associated with the Various Structures -

A Iliorough hazardous materials survey was performed for the installation by Camp Dresser & McKw Iiic.. (CDM 1988) and is presented in their report Hazardous Waste Manazement Remrt: Audit of 'l'iitpc~l l~,icililiw,USA Yuma Proving Ground. The assessment provided an overview of waste li~iiidlin~;pr.iclices and documented a few cases of improper use and disposal of hazardous materials. - -

3 - 146 Sitic.tv lhi* issuance of the CDM report, these practices have been corrected. The installation has insliliilionalizcd and enhanced environmental management practices. All environmentally unacceptable practices have been temiinated and the various YPG activities have been made accountable for their rc.spcvtivc wastes. All waste oil is picked-up for recycling or disposal by private contractors through 11w I ~i~luisisI

Iti iidtiition to hamrdous materials which are stored in the various facilities, some structures also wntiiiti iisbestos. A complete asbestos survey was performed for YPC; by Schrader Architects and issued oti Sipcinbcr 25, 1989. This survey included the inspection of 490 buildings. The survey revealed that (17 111 Ihcw buildings contained asbestos. Of the buildings containing asbestos material, 44 contain vinyl iishc*sltrstile which, if left undisturbed, is non-friable and presents no immediate hazard. Additionally, thtw iire approximately 18 buildings which contain some form of thermal system insulation which is, or could become friable, and does present a hazard if exposed. Finally, there are approximately 15 buildings which contain transite board which, if left undisturbed is non-friable and presents no inmidiate hazard.

Y.3.4.6.2 Hazardous Materials Associated with the Land

111 Ihc report prepared by the United States Army Toxic and Hazardous Materials Agency (1ISA'I.I IAMA 1988)' a chemical burial area, open buming/opcn detonation (OB/OD) areas (thrcc), a lixl iirscmte burial area, a diesel spill from a petroleum, oils and lubricants (POL) bladder tank, ~psolinvspills and battery acid neutralization pit have all been identified. This report dealt with sites thi11 were opriitcuf prior to 1980 and were all abandoned prior to that date. The sites were included in a Solid Waste Management Unit Report to the USEPA. The battery disposal pit was identified and closed in 1YH5. I'CU transformers were also identified and taken out of service. YPG has made a ccit~crlodcffort to remove all stored waste products and contaminated soils. This is being actively pitrsittd and evaluation of past activities is proceeding as funds are appropriated. In an earlier report by USAI'I IAMA (1980), four sanitary landfills were identified on-site. Currently, five inactive landfill sitt.5 c-xisl. Currently, there is one active landfill that is used for disposal of sanitary refuse. The landfills *in' ttsid !'or the disposal of sanitary refuse and empty pesticide contaiiiers.

Y.3.4.6.3 Vue1 Storage

1:itt.l prodiic~sare stored at the service station facilities within the Main Administrative Area which wnlalin lip lo 00,UOO fi.illons of gasoline, 1,800 gallons of bulk waste oil and some waste products at lhri*t*wldlitc storagc facilities. At the Mobility Test Area, up to 138,500 gallons of fuels and 14,850

3 - 147 2 w..".

I_ Y c2" I

'LI 0

. --- 3- 148 . A. '8

3 - 149 - ~;iiIloiisof oils and lubricants are stored. Jet fuel is stored at the Laguna Army Airfield and Castle Dome I ldiporl iind 20.000 gallons of gasoline and diesel and 500 gallons of waste oils are stored at the KO. Iking Ihige. In addition, YPC has tanker trucks with a total capacity of 37,500 gallons. YPG conducts ~- Icuk tc-slin~of tanks under a petroleum, oil and lubricants contract. .. \.3.4.(1.4 k4ai.ardous Materials Associated with Projectiles

I Iiizardous materials stored at YPC include high explosives and white phosphorus artillery and - niortiir ainmunition, propellants for such projectiles, various fuels and projectiles containing depleted iir.iiiiiiin iiiid beryllium. Ammunition and propellants arestored in 19 igloo facilities located in the Kofa - liriiig ILinge. An Ammunition Preparation Facility is located at the range and is used for preparation iiiid modification of all calibers and types of standard and developmental munitions and small rockets. ‘fhe cumplex serves as storage for propellants, fuzes and other sensitive explosives. The facility has the - capability of storing 4-1 /2 tons of explosive items. -. ‘I’hc KFK is the primary range used for artillery and mortar weapons and munitions testing. There iiro holh fixed and temporary locations for firing positions. All gun positions are improved sites to v.irying degrees. Range instrumentation as well as conditioning boxes aiid environmental simulation -. f.icililies are ustvl to perform ammunition safety and environmental tests. ’ Approximately 50 percent of tlk inslallation’s testing effort is concentrated in this area. The number of ongoing concurrent tests - ,it ‘iny point in time averages from four to five. Testing at the Cibola Range is performed in suppo of thc aircriift armament portion of the mission. These tests generally occur at the 2.75 inch Target Array, moving target, rocket alley, and Prospect quare ranges. UXO resulting from testing of --. iiiiriiilions poses a hamrd to both developed and undeveloped impict areas. Special procedures have IJ~YWdevc.lopcd fur demilitarizing these items as they are encountered on the firing range. This consists - of cxplosivc ordnance disposal personnel generally detonating the items. A hazard is created when not all explosive test items are recovered and they remain in the impact areas often times armed and fused. _- Of particular concern is the hazardous nature of projectiles manufacturtd from depleted uranium

(IN) and its effect on the KFR area north of Pole Line Road in which these rounds are fired. .- Addilioiially, IIU impact areas have been identified in the northern reaches of Castle Dome Wash and cwl of llig liye Wash at the southernmost point of the Castle Dome Mountains. Currently, potential Iiiiziirds to personnel and the environment are mitigated by an environment;il radiological plan which - iiionilors iiny migration of DU outside of the restricted areas and assures that cleanup of DU takes place

3 - 150 CHAPTER 4 - ENVIRONMENTAL AND SOCIOECONOMIC CONSEQUENCES

4.0

'l'hc cnvironmental and socioeconomic impacts addressed in this chapter are associated with the closurc of JPCand the potential implementation alternatives at YPG. Areas of environmental concern identified at JPC that cannot be fully addressed due to lack of baseline data (as presented in Chapter 3) include the potential presence of threatened and endangered species and the level and extent of contamination to soils and water resources. Thii chapter addresses hazardous materials to the extent that they affect or are affected by closure or realignment.

The Army will prepare a Natural Resources Management Plan that will address threatened and endangered species, species of concern, game management, wetlands and other resources at JF'G. Thii plan will comply with 32 CFR 265 and all other applicable laws. Timber Management will be addressed in this natural resources plan. A sedimentation and erosion control plan also will be prcparid and implemented in order to minimize impacts due to runoff and erosion.

At JIC, the Army plans to conduct both an RI/FS of the cantonment area south of the firing line and a sampling program of selected sites and all streams to determine if contamination is present in concentrations that would be hazardous to the public or the environment. Any remedial actions that may bc rquired based upon the results of these studies will be addressed in subsequent NEPA documents. This EIS is not intended to address impacts associated with potential remediation activities at JPC.

Each of the categories of environmental and socioeconomic baseline sections presented in Chapter 3 arc discusscd in Chapter 4. Impacts and potential mitigative measures for the closure of JPG are rrportcd in Section J. The impacts and mitigation associated with the proposed action (intensification of use of the central Kofa Range) and the implementation alternatives (realignment to the East Arm) lor YP<; are presented in Section Y.

4- 1 VING

1.4.1 NATURAL ENVIRONMENT IMPACTS

1.4.1.1 Cliiiiate

Activities associated with closure of them will not have impact on the local or regional climate. Since the closure of JPC will not have an effect upon the regional climate, no mitigative measures are rcquircd.

J.4.1.2 Topography

The cessation of all testing activities would have a positive impact on topography in that further alteration of surface features by exploding ordnance would be discontinued. Impact zones currently cleared of vegetation will naturally revegetate, thereby decreasing potential surface erosion. Existing surface erosion problems will be minimized by implementing an erosion and sedimentation control plan. Implementation of such erosion controls will ensure that negative changes to topography are minimized or eliminated.

J.4.1.3 Ceology and Mineral Resources

No significant impacts to geology and mineral resources at JPC will occur as a result of closure. Since closure docs not include mining activities, available limestones would not be quarried on the inskdlntion property because of the widespread presence of unexploded ordnance. Since the current activities at JKwill not have an effect on the geology and mineral resources of the area, no mitigative measures are required.

1.4.1.4 I'aleontology

{Jniquc or unusual paleontological formations are not known to exist within the installation. 'l'h(wkirc, impacts associated with the closure program are not expected and mitigative measures are not proi)owd

J.4.1.5Soils

Almost a11 of the activities that impact or potentially impact soils, including ordnance testing, disposiil of solvents, solid waste, red lead, sulfur disposal, use of pesticides, open burning practices and iiicincration have already been, or will be, discontinued with closure of JPC. The cessation of IIICW activities provides a beneficial effect for soils in that further additions of new contamination will

4-2 not occur. However, the contamination from past activities will continue to have long-term impact. Several of the solvent pits and landfills were closed and burning stopped several years ago, but DU, ordnance, USTs, solvent pits, and temporary storage areas remain as potential sources of soil contamination (USATHAMA 1990). The RI/FS planned for the cantonment area will provide inlomation on the nature and extent of soil contamination in this portion of JPG. The lack of complete da~ion present levels of soil contamination makes impacts difficult to determine. Nonetheless, the closure action would be beneficial to soils by cessation of any new disposal in soils.

Sincc the combined soil types that border JPG streams are erosion-prone Avonberg and Hickory silt loam, it is anticipated that once JPG is closed, the potential for continued erosion will exist. An rrosion and sedimentation control plan will be developed and implemented in order to mitigate these potential impacts.

Timbering has been proposed while JPG is under caretaker status. Timbering will cause increased erosion in areas which are cleared to any great extent. Selective harvesting will cawfar less erosion. An erosion and sedimentation control plan will provide methods to mitigate potential erosion in timbered areas. Methods that effectively reduce the disturbance of surface soil include: a) the use of broad-based road dips for sites with noticeable topographic changes; b) the use of site preparation techniques that do not disturb the surface soil; and c) felling and skidding controls near stream courses.

J.4.1.6 Water Resources

J.4.1.6.1 Groundwater

It is not cxpccted that there will be any groundwater use after JPG is closed. The primary activities that have affected or potentially impact groundwater, including ordnance testing, burning, landfill dumping, and solvent disposal, will be halted with the closure of JPG. The cessation of these activities will provide a beneficial effect for groundwater. However, the DU, unexploded ordnance, pesticide and herbicide residuals, underground storage tanks and solvent pits remain as potential sources of groundwater contamination (USATHAMA 1990). Solvents are no longer being disposed. One landfill exists for construction debris, other landfills are not currently in use, and burning only occurs in steel pans. Closure will eliminate further additions of new sources of contaminants to the groundwater. I lowcver, the lack of comprehensive data on present levels and/or the extent of groundwater cont;rminntion makes impacts difficult to assess.

(;round water could migrate off-site and contaminate drinking water wells. The closest potential sour('<>of groundwater contamination to off-site users is the Gate 19 Landfill. Two rounds of sampling dat~ill 1988 has shown no evidence that contaminants have migrated off-site. However, the

4-3 n~oniti~r~ngwells will be re-sampled and the configuration of the monitoring well network will be re- examincd to insure that it is adequate to detect offsite contamination.

1.4.1.6.2 Surface Water

Current and past installation activities have the potential to impact surface water quality. The discontinuation of current activities will have a beneficial impact in that no additional potential sources of contamination will be created. As an example, the closure will result in a significant reduction in the wastewater discharge from the on-post sewage treatment plant. Herberts Creek will hnrfit from this reduction of treated discharges.

Surface waters may also be affected by the contribution of existing pollutants from soils which already been contaminated. Such pollutants could migrate horn soils to surface water during rainfall events or via groundwater. Use of erosion and sediment control measures will reduce erosion due to surface runoff.

The lack of sufficient surface water and sediment data makes it difficult to assess current impacts to surface water. The Army will collect surface water and sediment samples fromm all stream traversing the installation as part of a program to determine if contamination is present in concentrations that would be hazardous to the public or the environment.

Continued timbering will result in increased runoff of soil material and any associated contaminants from cleared areas, depending on the type of harvesting method used, and the degree of (ont,iininatwn within the cleared or harvested area. Adverse impacts on surrounding aquatic areas cauvrl by harvesting techniques will be minimized by a sedimentation and erosion control plan. This crowon plan will include the use of broad-based road dips for sites with noticeable topography chanpb, the use of site preparation techniques that do not significantly disturb the surface soil and fclliri~controls to avoid stream courses or quick removal of whole trees from the streambed.

1.4.1.7 Aquatic Resources

~1'111~lack of baseline data on benthic invertebrate communities and water quality makes these inipicts difficult to determine. Sport fishing, currently practiced in Krueger Lake, Old Timbers Lake and several ponds, will be discontinued once JPGis closed. The stocking of fish will also no longer be practicid. Other potential impacts on these resources can include water runoff carrying pesticides and herbicides from treated soils, particularly the impact fields. Implementation of the erosion and scdiincntation control plan will ensure that potential impacts to aquatic resources are minimized.

4-4 1.4.1.8 Terrestrial Ecology

J.4.1.8.1 Wildlife

Generally, the cessation of the stin mission at JPG is predicted to have beneficial mpact to wildlife due to a decreased level of disturbance. Public access will continue to be strictly regulated and controlled thus protecting wildlife resources f?om human disturbance and predation. Protection and isolation of sensitive wildlife habitats will continue after closure.

I lunting for whitetail deer, and other game species, will be continued on a strictly controlled lottery basis. The maximum number of hunters allowed on the property after closure may increase duc. to the cessation of the mission (Knouf, personal communication, 1990). Since prehunt populations of JPG Whitetail deer are estimated to be from 40 to 66 deer per square mile Veldt 19871, controlled harvests will continue as a management tool to minimize the impact of closure. It is currently unknown what agency would manage the hunts. Without a controlled harvest, the deer population is likely to increase rapidly, causing disastrous consequences to both the herd and the surrounding environment.

I)cvclopment and use of the Natural Resources Management Plan will facilitate the effective management of the existing resources. Continued timbering planned during the caretaker period is not expectcd to cause significant impacts to wildlife.

Adverse impacts due to closure of the JPG installation would occur from the cessation of prrscribcd burning. The size of the bum, amount of forest edge, and interspersion of openings with diflrrrnl kinds of cover types positively influence the response of specific species that rely on early srirc~*ssionalhabitats (Bendell 1974). The habitat conditions created by burning include: an abundance of vegetative growth near the ground; and growth of scrubshrub and large fruits and svcds that may be retained on the plants (Bendell 1974). Several species such as the Bachman's sparrow and I Ivnclow's sparrow rely on habitats created by controlled burns. The ending of any prescribed Iiurnirij; program also will beadverse to the bobwhitequail population. Natural succession will result in tnoro niaple/sweetgum stands that have minimal value to the species. Ceasing current prescribed burns (10,000 to 15,000 acres per year) would curtail benefits to species requiring ecotones (transition xon(.s bctwccn two or more vegetation communities) and open, grassed areas for food and'shelter. Thc IcveI of impact is expected to be minor over the short-term Natural revegetation of impact zones may offsel the loss of habitat. However, it is unknown if these zones could be safely used by wildlife due to potential UXO danger. The Army plans to continue land and natural resource management practices. Further NEPA analyses will be performed if these practices are curtailed. .

4-5 Ilcnclicial impacts to wildlife include the strictly controlled and regulated public access, continued potcurtion of sensitive natural resources, the cessation of noise disruption, and the alleviation of additional contamination. Protection and isolation of sensitive wildlife habitats, suchas the great blue hcron rookery located on Graham Creek, will continue under closure.

Spccies of Concern. Threatened and Endaneered Wildlife

!+vera) Federally listed endangered, state endangered/threatened or state species of concern are known to exist in the immediate vicinity of the installation. No adverse impacts from closure are prcdictcd for those species that are considered transient. The Indiana bat has been reported in several karst areas adjacent to the installation. Timbering near caves and/or hollow trees will be avoided in order to minimize potential impact to the Indiana bat's habitat if survey results indicate this necessity. Other measures recommended by USFWS should the Indiana bat be found are provided herein (I ludak 1991). Individual timber sales and management activities along potential Indiana bat foraging streams should be subject to separate and individual review (Hudak 1991). Hardwood forested corridors (100 feet on each side of all intermittent streams and 200 feet on each side of all perennial streams) should be managed to avoid potential impacts to the Indiana bat. All dead trees of all species, regardless of their relationship to streams, with at least 9 inches dbh in size should be rrtaincd. Along all perennial and intermittent streams, timbercutting should be prohibited withii the forestid corridor during the Indiana bat maternity period, April 1 through August 15 (Hudak 1991). A survey is planned to identify habitat and verify the presence of the Indiana bat (Federally and state endangerd). Results of the Indiana bat survey will be incorporated into the Natural Resources Management Plan in order to avoid potential impacts. The Natural Resources Plan will address threatcncd and endangered species and species of concern. This plan will comply with 32 CFR 265 and a11 other applicable laws.

Stw*ral wetlanddependent Indiana State endangered birds like the sedge wren (Table 1.3.1-4) could bc adversely impacted by timbering in or adjacent to wetland areas. Establishing buffer zones around wctland areas will minimize potentially adverse impacts on these species. The Bachman's sparrow, a state endangered species observed within the installation, occurs in open pine woods with thick undcrgrowlh. Timbering in this habitat type could displace this species. The upland sandpiper, a stah' endangered species reported in close proximity to the installation. inhabits open meadows and li(.Ids. Under closure, the lack of prescribed burning in or adjacent to this habitat could impact this S~KIL~S.The Ikwick's wren, loggerhead shrike and golden-winged warbler (State endangered species) inhabit open woodland/scrub-shrub areas in close proximity to the installation. Under closure, the lack of prcscribcd burning could adversely impact these species and associated critical habitats.

'l'hc bobcat, a state endangered species, inhabits mature forest and wetland areas within the installation Any human disturbance in the vicinity of this habitat could impact the species. Under closurc, rllc curtailment of prescribed burning could limit the hunting areas of this species. The bobcat

4-6 w~llbv surveyed in 1991. Results of the survey may help minimize any potential impacts due to

(41 1\11 I I.

Potential impacts to the northern red salamander and the hellbender, state endangered species, due to increased runoff and sedimentation will be minimized by implementing an effective erosion and sedimentation control plan. Henslow's sparrow, a state threatened species observed within the installation, could be adversely impacted by the curtailment of controlled buming. The sedge wren, another state threatened species, is not expected to be affected by closure.

The evening bat, a state threatened species with habits similar to the Indiana bat, could be impacted by timbering. The four-toed salamander, northern copperbelly water snake and the Kirtland's water snake (a Federal "Category 2" species, and state threatened species) could be impacted by any activity causing water quality degradation and/or wetland destruction.

To avoid impacts, a Natural Resources Management Plan will be developed that addresses threatened and endangered species and species of concern. Wetland habitat will also be a component of the resources management plan. The plan will comply with 32 CFR 265 and all applicable laws.

J.4.1.8.2 Vegetation

'l'lie cc3sation of munitions testing and other activities that affect vegetation, such as herbicide application, soil sterilant application, prescribed burning and physical damage due to artillery impact will allow normal successional growth pattern to resume. The testing areas will eventually become scrub/shmb areas ultimately leading to mature forest. A small grove of bald cypress trees growing in thr east central area of the testing range, adversely impacted by test firing operations (USACE 1988), would also benefit from the cessation of testing operations. The three areas designated by the Indiana Ikpnrtmcnt of Natural Resources (IDNR) as "areas of excellent natural community values", will remain undisturbed under closure.

C'ontrolkd commercial harvesting of timber will continue. Adverse impacts on surrounding vqylntion and aquatic areas caused by harvesting techniques will be minimized by the sedimentation and i-rosioii control plan. This plan will include the use of broad-based road dips for sites with noticcablcs topography changes, the use of site preparation techniques that do not significantly disturb tlic siirLicc soil and felling controls to avoid stream courses or quick removal of whole trees from the strr.iinhcd. A timber management plan will be included in the Natural Resources Plan.

4-7 Spcyicbs of Concern, Threatened and Endaneered- Flora

JIK has never been systematically surveyed for endangered species of plants. However, one 1;edcrally endangered plant species, running buffalo clover, potentially occurs within the confines of tlic instalL~tion.This plant prefers well drained sites in woodland areas and, if present, is not expected lo br afftrtd by closure.

Timbering activities could adversely impact the smooth white violet, a State threatened species recorded within the installation boundaries. Mitigative measures and species specific management plans will be developed following the species surveys planned for the winter of 1991/1992. This information will be incorporated into the Natural Resources Management Plan.

1.4.1.9 Wetlands

Closure is not expected to negatively impact wetlands on JPC.The cessation of current JPG testing activities would be beneficial to this natural resource. Although some negative impacts could continue because of existing contamination on the property from surface water runoff, the potential for greater impacts would be diminished. The lack of any formal surface water monitoring data prohibits making conclusions about the effects of runoff on wetlands.

Clearing or extensive harvesting in wetlands during timbering operations could be avoided. Slcct~dharvest will have far less effects. The effects of timbering on wetlands will be influenced by all applicablc Federal and state regulations. Under the latest Section 404 regulations, certain land clearing activities are subject to the Corps of Engineers permit process. If heavy machinery is used to conduct clearing during timbering in jurisdictional wetlands, a 404 permit is required. Adherence to thesc regulations will result in avoidance and minimization of impacts to wetlands. Implementation of erosion and sedimentation controls in forested wetlands will also minimize potential negative inipxts on this resource. Wetland management strategies will be included in the Natural Resource l’lan

J.4.2 AIR QUALITY IMPACTS

Air pollutant emissions associated with open burning of excess propellants and detonation of cxplosives, lire training, traffic and other normal operating activities will be reduced or eliminated iipoii closurc of JI’C. These beneficial reductions are not expected to result in significant air quality ctiangcs to local or regional air quality. Asbestos material that presents an airborne health threat is currvritly being rcmediated (USATHAMA 1990). Therefore, no mitigative measures are required. J.4.3 NOISE IMPACTS

A beneficial impact of closure of JPG will be the elimination of noise associated with the testing function of the installation, such as tank, artillery, mortar and blast events. Elimination of the bombing and strafing practiced by the INANG also will reduce the existing noise levels generated in the northwestern sector of the installation. No mitigative measures are proposed for noise.

1.4.4 HUMAN ENVIRONMENT IMPACTS

J.4.4.1 Visual and Aesthetic Qualities

Closure of the JPG would end the ordnance testing that is currently responsible for impairing the aesthetic appeal of the post. The closure action would eliminate use of the facility, thereby reducing the number of people available to enjoy the visual and aesthetic resources JPG offers. No mitigation is proposed to reduce this minor impact.

1.4.4.2 Native American Concerns

'l'hc closure of JPG would result in no impact on Native American values.

J.4.4.3 Archeological, Cultural, and Historical Resources

'I'he closure of JPG would result in a finding of no impact on the cultural resources located within Ihc JI'C installation. The four County Bridges and the Oakdale School have all been determined to be c.lig:iblc for the National Register, and the Old Timbers Lodge is potentially eligible. A detailed assk'ssment of the integrity of all of these properties would be necessary if any adverse impacts were prtrposed. The Army will ensure that any standing structures determined eligible for inclusion in the National I

J.4.4.4 Zoning and Political Boundaries

Onw closurc occurs in EY95 the facility will cease to perform a designated Army mission but will I-cniciin as Army controlled land lor property management purposes until final disposition

4-9 action is taken. Local municipal boundaries and community land use regulations will remain unchanged upon closure and subsequent caretaker operations.

J.4.4.5 Socioeconomic Characteristics

The primary source for the quantitative information generated to assess specific socioeconomic impacts is the Phase I1 Socioeconomic Effects Analysis (SEA) Report prepared for the proposed action by the Institute for Water Resources (IWR). The IWR quantitative analysis specifically applies to the subsections below on population, economic activity, housing, and schools. IWR made use of the ('onstmction Engineering Research Laboratory (CERL) Economic Impact Forecasting System (EIFS) model to quantify the socioeconomic impacts associated with closure and realignment activities. The SEA Report for each installation is on file at the U.S. Army Corps of Engineers, Louisville Dishict.

'l'hc numbers provided in the analysis should be considered as approximate. The goal of the modeling effort was to determine the potential magnitude of economic change and determine the ptcntial significance of such change. Impacts were considered significant if they exceeded certain par.imclers that would be associated with normal economic cycles within themor YPG region.

'l'he analysis conducted at JPC is considered a worst-case analysis based on a scenario of the complcle closure of the installation. The modeling effort did not make any other assumptions concerning other potential impacts or impact levels that could occur at the installation or the siirrounding region. Additionally, the model did not consider the effects of the caretaker maintenance prograin at JIG. As stated in Chapter 2, the effort would require an Army personnel staff to act as a "carc.takcr" until JPG property disposal determinations are achieved. IWR concluded that under a worst-case situation, closure related impacts at JPG will be considered significant.

1.4.4.5.1 l'opulation and Employment

According to the IWR Phase U SEA Report updates for JPG, a net total of 421 permanent vniployees, (407 civilians and 14 military) will leave JPC due to closure actions (Early, personal (-~ininiiinic,ltion,June 1990) (Table 2.2-1). The actions at JPG are expected to result in a 1,234 person d(ucwc*in rq;ioniil population. The total decrease will include 1,226 persons living off post. All of tIi(w- personnel arc assumed by IWR to leave the 1% region. The impact associated with the transfer of 1wrsonneI rcsprcwnts an approximate 1.6% decrease in regional population (based on 1987 levels). .I tic nirmlws prewnttd here are based on a worst-case scenario.

4-10 'l'lit~IWI< IXcport (1989) concluded that this change in population may be significant. The cxli(~.t(dikinjy in regional population and employment exceeds the Rational Threshold Value

(I('1.V) t 1.i1t~i.ideveloped by IWK to determine significance. The RTV method gauges the economic n.silicw.y of lire region in terms of threshold values representing the maximum of historic variation.

A\ pirt of the overall closure process, the Army will provide a caretaker staff during the period hctwit-n closure in FY95 and property disposal. Although specific details concerning caretaker pc*rx)iincl levels have yet to be approved by the Army, a caretaker workforce staffed by the Army would act to mitigate the worst-case SC€XIanO regarding the loss of all jobs at JFG.

Other mitigation efforts that will be taken by the Army to offset the potential adverse effects of closure and subsequent loss of employment would include:

'l'lie procssing of early retirement eligibles from the current JPG workforce. Approximately 140 ciiri-eiil JIGcivilian employees would be eligible for retirement.

I'nividing current JPC employees with the opportunity to transfer to workforce positions L.stablislicd as part of the realigned ammunition acceptance testing mission at WG. A rcc'ruilincnt assistance program would aid the Army in the recruitment of current JM; employees sufficientlyskilled to perform ammunition acceptance testing assignments at YPG.

I'roviJing JI'G employees with the opportunity to transfer to other DOD or non-DOD positions within the Federal employment sector. The DOD Priority Placement Program could be utilized by tlic Army to help employees find comparable employment within DOD.

J.4.4.5.2 Land Use

Upor (losure, the JI'C property will remain categorized as Federal government land. However, th(, vxi41ng ~nstallation land use patterns, with regards to current operations, will change \i):iiiIi( .iiitly cliic lo the closure and realignment.

All Iliiid 1151' oper,ilions and functions associatd with JPG's test niission will cease completely (i1lc.r dosure. Mosl of Jl'C's facilities will become deactivated during the process of mission rculil;iiiiitwt Lo YI'c;. When the transfer is complete and JPC is officially closed by FY95, and if no reux' options 'iIc iiiimcdiately exercised, all or part of the JPG will enter into a period of caretaker sldliib. Sl)cc.ific information concerning the caretaker status is unavailable at this time. It is cinli~ip~~l~d,Iiowcver, that some facilities will be required to support the caretaker program. The ~~ctiiii~~tc~f{*iici- will be swured and maintained to prevent public access and off-post land-use

4-11 cnc.r~i.icl~ment,preserve public health and safety, and protect government property kom illegal entry and v~ndalism. During the caretaker period after closure, there would be little effect on adjacent off-posl hnd use patterns.

Ilesource management activities during the caretaker period could increase on-post land utilization for the timber harvesting and deer hunting program cunently undertaken at JPG. The timber harvest program may be expanded to include additional acreage beyond the Current 15,000 acre management area located in the northern portion of the test range. With the curtailment of the test mission, additional hunting areas could also become accessible in an effort to help reduce the large dew population at JPG.

1.4.4.5.3 Regional Economic Activity

According to the IWR SEA analysis, regional losses and gains associated directly with closure and realignment actions are considered to be primary impacts. Primary economic impacts include the changes in the following parameters: personnel employed at the installation, their salaries, and procurement expenditures. No realignment-related construction is expected to take place at JPG during the closure transition period.

Srcondary impacts are those effects induced by the initial primary impacts. For example, a change in the regional demand for goods and services is induced by a regional change in the number of persons earning wages and salaries. Total reported impacts include all primary and scrondary impacts. The outputs of the IWR EIFS model relating to economic impacts likely to occur in the JKregion as a result of the closure action are summarized below as a worst-case scenario.

I(~~~il~~nmc.ntEconomic Impacts: The realignment actions will result in a decrease in the sales voluine for regional merchants of $47.7 million. The primary and secondary impacts will result in a 940 person-year decrease in regional employment, and a $17.4 million decrease in rc);ional income. Installation expenditures for goods, services, supplies and materials are cxpvctcd to decrease by $17.8 million.

Oiw'l'ime Expenditure Economic Imuacts: Onetime expenditures for housing assistance, worker placement, and other costs will total $6.0 million. All one-time expenditure impacts will occur during the realignment period of 1991 through 1995. The total primary and secondary impacts of realignment associated one-time expenditures will result in the regional sdles volume increasing by $2.1 million, regional employment increasing by 24 person-years, and regional personal income increasing by $246,000. -

4 - 12 Second lobs and Working Dependents Economic Impacts: A portion of the affected permanent military and civilian personnel and their dependents hold employment outside heir military-related jobs. Due to changes in personnel at JPG, the number of these non- military related second jobs will decrease by 15 full-time jobs and the number of working dependents is expected to decrease by 260 person-years. These job changes will decrease rcgional wages and salaries by $3.8 million. The total primary and secondary impacts of the change in the number of personnel holding second jobs and working dependents will result in decreasing regional sales volume by $5.0 million, decreasing regional employment by 333 person-years and decreasing regional personal income by $4.4 million.

Summarv of Economic Imoacts: All actions at JPG are expected to decrease regional sales volume by $45.0 million, decrease regional employment by 907 person-years, and decrease regional income by $17.0 million. All closure related actions are to be completed by September 30, 1995.

The expected decrease in regional sales volume, employment, income, and population within the JIC area represent respective decreases of 5.3%, 2.6% 1.9% and 1.6% of their 1987 levels. The significance of these impacts is viewed in terms of the overall change in regional conditions. Significance also is determined by the RTV method and by evaluating the "normal" fluctuations experienced by the region (the Forecast Significance of Impacts procedure). These methods compare the inipncts of a proposed action to the historic fluctuations experienced by the region. Applying these methods, it is concluded that the four major impact areas evaluated (sales volume, employmcnl, income and population) will, in the short-term, exhibit degrees of regional economic ch,inp' L~JI may be significant.

1 .o(dI economic concerns associated with the overall base closure program prompted Congress to iutlitrrize economic adjustment and community planning assistance in The Act. This assistance would help local communities offset the potential economic impacts that could occur with the closurc~of military bases.

'l'hc. JI'G I

4- 13 'l'tic JPC Board and the OEA are working to reduce the economic dependency of the area on JPG and diversify the private sector economy. Success in this effort would mitigate adverse economic impacts. Emphasis on non-military economic growth, could act to offset expected adverse impacts.

1.4.4.5.4 Housing

According to the worst+ase scenario utilized in the IWR Report (1989), a 407-unit decrease in the total number of occupied housing units within the JPG region would result from the closure of JPG; of these 92 are owner-occupied units and 315 are renter-occupied units. This represents 1.5 percent of the total year-round housing units (27,902) in the region as determined from 1980 census figures.

'l'he region's housing vacancy rate was 7.5 percent (2,093 units) in 1980. Based on this vacancy rate and assuming no new residential construction during the 1980s in the region, the initial impact could increase the potential vacancy rate to 9.0 percent. In addition, it is assumed that the 13 on- post housing units would be vacated by current military personnel attached to JPG.

Although an RTV significance factor was not attached to the housing variable, the expected dccreasc in occupancy of off-post housing units as analyzed by IWR is assumed to be significant. The overall net effect of the closure action would be a reduction in the local demand for owner- occupied and renter-occupied housing units. However, many JPG employees are widely distributed throughout the region and, in some cases, outside of the designated JPG region. Such a condition could partially offset the assumed significance of impacts resulting from an increase in vacancy rates. Housing vacancy rate impacts as assumed by IWR's worst case analysis could, therefore, be widcly dispersed and not concentrated within a single municipality and thereby lessen overall imp.icLs to the local real estate market. The caretaker program could act to mitigate the worst case swriiirio. Although specific staffing requirements have not been approved by the Army, caretaker pcrsorincl would require housing in the area and could include employees currently tasked to the J I'( ; lest or support mission.

Available measures to mitigate adverse housing and real estate associated impacts could include thc Ilomcowners Assistance Program (HAP) and the Department of the Army Relocation Services for Iimployws (DARSE). Should a substantial decline in the local real estate market occur during the impl1,iiiciitntion of the closure process at JPG, the HAP could be activated to help military and civilian eiiiployees choosing to relocate to other DOD or Federal job locations outside the region to sc4 their homes at a reasonable price within a reasonable time. Civilian employees choosing to tr.iiisfvr to other positions within the Department of the Army, such as the YPG area, may be di~;il)lvlor the DARSE program, which guarantees home sales and provides relocation assistance.

4 - 14 J.4.4.5.5 Schools

Under the worst-case conditions of the IWR Report (1989) the closure of JPG would result in a decrease of 230 students of JPC dependents attending public schools in the region. The study, however, does not identify which schools in the region would be most affected by the loss of c~nrollmcnt. The schools in the region having the largest enrollment of JPG school age dependents arc: Madison Consolidated (141), Southwestern Consolidated (46) and South Ripley County (37). It is also known that there are a total of 314 JPG dependents attending a total of 22 separate school districts throughout southeastern Indiana and northern Kentucky. The IWR study did ,not determine a significance factor to impacts associated with losses in regional school enrollment due to tlic closure of JPG. The wide dispersement of JPG students throughout the area could potentially Iessc~nthe impacts to any one school district in the region.

‘l’he caretaker program at JPG could act to mitigate the worst-case situation analyzed by IWR. ‘l’lic stall would require educational facilities for school age dependents. Specific caretaker staffing reqiiiremcnts have not been approved by the Army. Other forms of mitigation to aid school dislricts offset potential enrollment losses are limited.

1.4.4.5.6 Health Care

Impacts to regional health care providers are not expected to be significant, given the wide geographic disbursement of JPG employees and their dependents throughout the southeastern Indiana and northern Kentucky area. There are many health care facilities and hospitals located within this large area from which JPG employees and dependents are able to choose. The many hcvllli car(%facility choices spread over such a large area could act to dilute any significant impacts ki individual facilities.

1.4.4.5.7 Public Safety

A securily staff will be employed to patrol the grounds and monitor JPG‘s Intrusion Detection Systcmi lo prevent unauthorized public access as part of the Army’s caretaker program. Ongoing i~~,~inteni~riceof the facility during the caretaker program will maintain the perimeter fence to conlinue to provide the required public welfare and safety.

Chcc closure is complete there is the possibility of a short-term impact to public safety. With the c(,!+alion of a noise deterrent, closure may create an attractive nuisance. Civilians may seek uiwitkliorizcd access to the installation for a variety of reasons including: poaching, scavenging and curiosity. I’oaching of the abundant wildlife found on the installation has been an ongoing problem

4 - 15 '11 JIY; I'oaching and other unauthorized activities could present danger to trespassers because of Liqy amounts of unexploded ordnance in the area. The existing impact fields currently in use are pr(*siiin.ibly easily identified and avoided. After closure, pioneer plant species will begin to cover I1ic-s~inip~t fields making them difficult to differentiate from safer areas. Currently, all public s,rfc.ty functions at JPC are carried out with in-house personnel and equipment. This arrangement is c*xpcy tcd to continue during the Army caretaker program.

1.4.4.5.8 Traffic and Transportation

Under the closure action, minimal short-term impacts regarding safety, air quality and highway maintenance costs can be expected to occur. The impacts include:

I lie relatively low Annual Average Daily Traffic (AADT) figures and rural nature of the area are a contributing factor in classifying these impacts as minimal. The on-post road system will expc-riencc similar short-term impacts. On-post roadway maintenance and repair costs and traffic volunic. will bc significantly reduced.

'ktramition stage of the closure action could affect local land transportation systems, with weird lo public safety. It will be necessary to transfer large amounts of existing equipment from J1YPtu YI'G, a distance of 1,900 road miles. These materials will include weapons, ammunition, high explosives and other munitions associated with JPG's test mission. The peak time of transfer will be froin 1W3 to W95. It is assumed that this transfer of materials will require trips via the local highway network, since the JPG on-post and Madison Rail Spur to North Vernon is badly dcwiorcitcd and unreliable. During the transfer period, applicable safety guidelines regarding the tr'iiiqwrt of ni,iteriel will be followed.

11 i.z I~OLanticipated that significant impacts to regional transportation system components wiU oi'cui

4 - 16 J.4.4.5.9 Wastewater Disposal

'lhe closure of Jl'G will result in a significant reduction in the quantity of waste within the wastewater stream currently being discharged from IPG's on-post sewage treatment system. The system is designed to self generate flow to support the sewage treatment system regardless of usage. Rculuction impacts include:

Significant reduction of potential environmental sewage-related contaminanb; Significant reduction of treated liquid stream discharges into Harberts Creek; Elimination of dry sludge disposal; and, I'otcntial elimination of the short-term need to replace 27,000 LF of deteriorated and deficient sewer lines that had been programmed for replacement, thus saving the Army significant funds.

As with all other JPG facilities, current sewage system flow will be cut back in a phased manner. As a building is closed, the sewer lines from that building will be flushed out so that the majority of the system will be clean and better maintained for potential future use.

J.4.4.5.10 Solid Waste Disposal

During the process of mission realignment and deactivation of the JPG installation, a short-term increase in solid waste generation could occur. This increase would be the result of denctivation/cleaning of facilities and disposal of old equipment and materials. It is not known whtw* thc~Army will dispose of such solid waste materials (on-post disposal sites, off-post landfills, or otlier IX)I> siks). If local, off-site landfills are used, remaining life expectancy of these landfills could bc rculuced, but not significantly. Currently, JPG's single disposal site is in compliance with all statc and f:deral solid waste disposal regulations and is used for non-hazardous operational refuse. All sanitary refuse is disposed of through a private contractor.

Once thc actual process of deactivation is complete and the mission has been fully transferred to YIY,, Ihr solid waste disposal requirements of the installation are expected to significantly decrease. It his not yet been determined whether the Army plans to continue the operation of the on-post dlqwul arw Such a decision would involve the continued compliance with existing and potentia1 futurc~c~nvironmental permits governing its use.

Strbscquent to deactivation there will be a significant reduction of sanitary refuse produced at JIY;. 'l'hc existing contract with the private refuse contractor for sanitary refuse could be sigiiilii~iii~lyaltered or eventually eliminated, thus impacting the local contractor. Local landfills

4- 17 IIWYI Iiy 111c <

w,lrll. ]I1<;. This is not expcrtd to be a significant impact on the remaining life vxlx.c't'iiicy of area landfills.

J.4.4.5.11 Recreation

jIY; IS ,in abundant natural resource area and an excellent facility for outdoor recreation. JPG recreational activities and facilities will be affected as a result of closure actions. JPG employees, rrsidents, dependents and others currently spend about 6,000 user-days per year for recreational activities Hunting will continue to be allowed on a lottery basis during the caretaker period. Cessation of the mission may also open up additional areas for hunting. Therefore, the potential loss of user generated revenues from Licenses, fees, and permits may be offset by fees levied during caretaker status. Old Timbers Lodge is used by hunters during the deer hunting season; it is expcded that this arrangement would continue under the caretaker program. Therefore, the current usap- of 4,000 visitor-nights per year is not expected to significantly decrease.

A minor impact on all other forms of recreation offered to employees and dependents could occur. Krueger Lake, with its attendant ballfields, camping and picnic areas, the quarter mile jogging trail and ball fields in the family housing area, the campsites and boat ramp and rentals at Old Timbers Lake, and other recreation areas located throughout the installation may no longer be available for use by JPG personnel after closure. However, because many recreational opportunities exist at off-post facilities throughout the region, the impact of closure is not anticipated to cause a significant negative impact.

'I'hc closure will not significantly impact off-post recreational areas since many facilities are locatcd throughout the region. No off-post facilities are adjacent to JPGand none should be directly affected by closure activities. In addition, no single off-post recreation area should be significantly iiiili,xkd from closure activities. This is due to the fact that most employees live off-post and are widdy distributed throughout the region and have access to many recreation areas and op~~ortunitics.

J.4.4.5.12 Utility Systems

'I lie closure action at JPC will result in a significant reduction of utility service demand rc~pirc~mentsover existing mission support levels. The reduction will occur in a time-phased manner coiwstent with the mission transfer requirements to YPG. As the workload is transferred, buildings, plants, and other facilities will be closed and secured. Supporting utility systems will be deactivatcd and appropriately protected and secured for potential future use, should the need arise.

4- 18 It IS not anticipated that on-post utility systems will be completely deactivated or shut down. The Army will continue to operate each system at minimum design levels to support the caretaker pro);ram and provide general maintenance services to prevent the systems from deteriorating beyond Ihc point of future operating effectiveness. Specific details regarding caretaker service needs or utility system niaintenance levels have yet to be determined by the Army.

Impacts lo the utility service providers do not appear to be significant over the long-term. The servicr level demand requirements for electrical power and water are not extensive when compared to the overall service level output of PSI (electricity) and the City of Madison Water Authority (water supply). The contractor currently supplying #2 heating he1 will not be immediately affected, since JI'G closure of facilities will occur over a two to three year period.

1.4.4.6 Hazardous Materialflastes

'l'he discontinuation of testing activities is considered to be beneficial rather than negative environmental impact at JPG because no new contamination caused by the firing of additional ordnance will occur. Theclosure of JPC will not change the potentia1 for contamination from existing UXO. I'hc past usage and disposal of hazardous materials will have a long-term impact. The level and extent of this impact is unknown.

The lcvcl and extent of the impacts from existing UXOs are unknown but represent the single };realest concern at the site. No area could be released without a survey and, if necessary, clearance of IJXO's.

'1 tie Army could retain JT'G in a caretaker status for an undetermined amount of time. There are no c~irrciitplans for conducting an installation wide RI/FS. An RI/FS will be conducted for the 3,000 cicr('mntiininent area. This RI/FS, including cleanup, will be initiated in October, 1991 and will be

( oniplvtcti in September, 1993. Separate NEPA analysis and documentation will be prepared in wppirt cil reuse and associated impacts.

'I tit. Ariny will fulfill its regulatory obligations under existing permits and licenses at JPG and will CIWC tlir oprn burning/open detonation units and USTs and submit a decommissioning plan. Closure of JIY; will rquire that a decommissioning plan be developed and approved by NRC, addressing co~ic~~rnsand cleanup associated with radioactive hazards of DU. The Army will comply with the rquireni~~ntsof the current NRC license and requirements for the provision of the decommissioning phi. 'I'he plan will be submitted before the decommissioning procedures begin. A schedule will be dcviwd indicating the estimated time the plan will be completed. The plan also will describemethods to prolcct workers, methods and processes to be used, systems and equipment, and land to be dcc.~inimissioncd(NRC 1989).

4-19 'l'lic. site-spdfic sampling and analysis will include samples from all the surface streams that traverse JPC. Groundwater samples also will be collected from groundwater monitoring wells that exist at an impact field (interior JPG's North area). These samples will be analyzed for UXO chemical constituents (including heavy metals), pesticides and uranium isotopes. The Army will conduct this smipling program to determine if contamination is present in concentrations that would be hazardous to Iwnian health or the environment. All areas having a significant risk will be remediated in accordance with law.

All USTs installed prior to 1988 throughout the United States will have to be either updated to new USIPA specifications or properly closed by December 1998 (USEPA 1988). Although JPG will eventually close or remove all tanks because of base closure, some USTs may have to be closed earlier than planned because of USEPAs schedule of closure for USTs of different ages. JPG will comply with USET'A and state RCRA requirements for the closure of USTs.

JI'C also has programs in place to evaluate and control asbestos and PCBcontainiig oils. These programs include personnel training and proper operating procedures. JPG has removed some asbcstos that was in a friable condition. JF'G has also been encapsulating the potentially friable asbcstos in the piping joints in the family quarters, office buildings, and workshops. JPG'sasbestos abatement program is expected to continue and will not be affected by closure. If the seven transkwmers with PCB's greater than 500 ppm are to be disposed of, it will be done in accordance with the 'I'oxic Substances Control Act CECA) and 40 CFR Part 761 rules.

I c*\t rcsults indicate background levels of radon gas at JPC structures are lower than USEPA's ncti~mIcvels Therefore, no further radon testing or mitigation measures are required.

4-20 Y -.jlVI IWNMENTAL AND SOCIOECONOMIC CONSEOUENCES OF THE REALIGNMENT -IO YUMA I’KOVING GROUND

Y.4.1 NATURAL ENVIRONMENTAL IMPACTS

Y.4.1.1 Climate

Implementation of the proposed transfer of the JPG testing mission to the YPG is not expected to create any impact to the climate of the area. No significant microclimatic changes are anticipated for the areas proposed for development since development is small and no surface water bodies or similar climatic altering features are proposed. This finding of no significant impact would also be true fur implementation alternatives on the East Arm. No mitigation measures are required.

Y.4.1.2 Topography

Construction of new facilities (implementation alternatives) on the East Arm of the YPG will rvcliiir~,morc substantial grading both for construction of buildings as well as the construction of .iccc’ss roadways both on-post and off-post. The associated impact to topography will be adverse, but iirit considercd significant, since most of the areas identified for facility construction under these altimwtives are not high in topographic relief. Therefore, no mitigation measures would be required uiirfr,l tlwsc. alternatives. New ranges would be required for each of the implementation alternatives

c’xccyt Iiir llic no new facilities alternative. Depending upon the required uses, construction of new inipict drccis may create signlficant topographic impacts. Mitigation measures would involve the rc~lii~~~tiiiiio[ faciliticu and impact areas within areas of lower topographic relief.

Y.4.1.3 (;rology and Mineral Resources

1i:i~~I~~ii~~i~t~tioi~of the proposed action will result in the construction of various facilities zm)ciCikdwith increased munitions testing at YPG. There is a potential that these faciliti? could be

4 - 21 signilicantly impacted by geological hazards such as seismically induced groundshaking soils. This potentially significant impact will be reduced to nonsignificant levels by conducting geological studies at each site. These studies will determine design considerations for foundations and assign seismic design factors to be used in design of facilities.

Use of the existing range facilities for the increased testing loads will not result in any further potctitial loss of mineral resources since the exploration and development of mineral resources in this amare already precluded by current munitions testing activities. The sites for placement of buildings and other structures do not contain any known valuable mineral resources. Alternative use of the East Arm of the post would have potentially greater impacts to mineral resources since additional areas would be contaminated by munitions testing, rendering them unusable for future mineral development.

Y.4.1.4 Soils

Implementation of the proposed action will result in the construction of additional facilities near existing testing facilities. Grading associated with this construction will have the potential to increase soil erosion in the area. This significant impact will be mitigated to insignificant levels by incorporating standard erosion control measures such as contour grading and bank stabilization.

Use of the existing ranges for increased munitions testing is expected to adversely, but not significantly increase the potential for soil erosion in the area. Of particular concern is the potential incrcascd contamination of the range soils with such material as UXO. Even though most of these artus have already undergone soil contamination to some degree, there will be increased ciiiitcitiiin~tion. Mitigation measures involve the exploration of methods for range cleanup and m,ina);cnient. Use of catch facilities for DU projectiles will minimize contamination of direct fire ran);(' soils.

Use of the East Arm alternatives for munitions testing will increase the potential for soil erosion both from facility construction as well as from munitions testing on the ranges. This potential impact is significant, but could be reduced to nonsignificant levels by standard erosion control ni~wiires. Of far greater concern will be the contamination of soils that at present are not greatly cont'iiiiinatcd with UXO. This would be considered a significant impact. Use of catch facilities for I )U projcsctilcs will minimize contamination of this site.

4-22 Y.4.1.5 I’aleontology

C’onstruction of the facilities associated with the proposed action is not expected to significantly impact paleontological resources due to the low potential for finding fossiliferous material Wander Zyl, pcrsonal communication, 1990). Significant paleontological materials are also not expected in lhc area of the East Arm where construction of the alternative Jeffersonville site would occur. ‘l‘hcrefore, no significant impact is anticipated.

Y.4.1.6 Water Resources

Y.4.1.6.1 Groundwater

Implcrnentation of the proposed action will result in the transfer of additional personnel positions to YPG and will require additional water for construction and operation of facilities. Since llic source of this water is from groundwater, there will be increased use of the aquifer. This will rcquire the drilling of an additional well.

An adverse, but not significant impact to groundwater resources is projected since it appears that the aquifer can safely handle additional projected use. Water quality is a concern since the groundwater is high in total dissolved solids and fluorides. This is a potentially significant impact, but will be reduced to insignificance by providing water treatment equipment on-site. It is anticipated that other implementation alternatives would have similar impacts to the proposed aclion except that several new wells would be required on the East Arm.

Y.4.1.0.2 Surface Water

Iiiiplcincnhtion of the proposed action may subject new facilities to localized flooding during Iicu vy rainstorms. This potentially significant impact can be reduced to nonsignificant levels lliroiij;Ii careful siting of the facilities away from washes and making sure that the facility is (.onslructc*dabove the floodplain for any sheet flow flooding potential. Construction of the facilities

‘is WCII :IS increased operations hithin the Kofa Range increases the potential for erosion and scdiiiwntation during the periodic heavy rains in the area. This impact is considered potentially stgiii~icanl but can be reduced to insignificant levels through incorporation of erosion control nicasures in thc project design.

A poteiilicil significant water quality impact centers around the increased use of the ranges for munilions testing. Depleted uranium use could result in surface water contamination. This would be rcducrd lo nonsignificant levels through the use of catch facilities. Potential surface hydrological

4-23 impcts would be similar for all implementation alternatives, the use of the East Arm for munitions tvstinl; would create a more substantial impact since this area has little contamination from such

Y.4.1.7 Aquatic Ecology

No iiiipacts to aquatic resources on the facility are anticipated by the implementation of the proposed action or its alternatives. There may be an impact to off-site resources due to release of minute amounts of chemicals such as DU. These levels are not anticipated to approach anywhere near toxic levels, therefore, the impact is not considered significant.

Y.4.1.8 Terrestrial Ecology

Y.4.1.8.1 Wildlife

Implementation of the proposed action will result in the loss of wildlife habitat near existing f arilities.'.' in and near the administrative area. It is expected that this will result in an adverse but not significant impact to wildlife since this area is already disturbed and the region has a relatively low wildlife diversity and habitat value. No impact to Federally listed threatened or endangered wildlife spc-cies arc anticipated as a result of the proposed action. However, formal coordination with the USI*WS(Appendix B) is in its preliminary stage and no opinion has yet been received. There is a poteiilial that the big horn sheep inhabiting the Castle Dome Mountains may be affected by noise associ.ilcd with the increased testing program. This is anticipated to be an adverse impact, but is no1 .inticipated to reach significant levels. There are unpublished reports of desert tortoise Occumng williin tlic Kofa Firing Range. Increased activity could significantly impact this species.

I'hc proposed action will intensify and potentially expand the use of the existing KFR. There will bc an increased impact to wildlife inhabiting the Kofa Range due to the increased testing and ~x~tentialhabitat disturbance. This area is currently subjected to artillery and mortar fire. The additionill impact will be adverse to wildlife inhabiting the area and this may be significant. Since no .\ystelncitic wildlife assessments have occurred in the KFR, the exact degree of impact cannot be cI(4tmiiiii

4 - 24 In r(>gard to environmental commitments, all proposed use areas will be surveyed for vegetation

.itid wildlife resources once detailed plans are prepared. This on going survey will also include an

(iii,ilyw I)( 111~impacts on a site-specific basis. I'roccdural methods such as no night time firing will lw dw~lop~d,if necessary, to minimize or reduce any impact below significant levels.

('otistruction of the alternative facility on the East Arm will result in significant .impacts to wild lilt^ due to the relative high diversity of wildlife in the area. Of particular concern would be the iiiupicts to large mammals, especially deer since this area supports a large deer population. Addilionally, there is a potential for impacts to the sensitive desert tortoise and the bighorn sheep occurring in the region. There is also a potential for noise impacts off the range associated with munitions testing in the East Ann.

Y .4.1.8.2 Vegetation

Implementation of the proposed action is projected to result in disturbance of from 75 to 100 acres of vegetation within the existing fireline and administrative area. Although sitespecific field surveys have not been conducted on the proposed facility parcels, it is anticipated that this impact to vcl:rt.ition will be adverse, but not significant due to the existing high degree of disturbance within lhc area. 'l'hcre may also be a potential impact to areas within the Kofa Range due to increased ran);(. tcsling. It is anticipated that this impact will be adverse, but not significant, due to the prcviws disturbances in the area. No impact to Federally listed threatened or endangered plant spc.ciL,s arc anticipated, however, formal coordination with the USFWS is underway. There is a potctitial that construction could impact the BLM sensitive spiny sand spurge which has been idrvililicd in the Main Administration Area. Site specific surveys would be required during the fall moritlis for this species.

C'onstmction of alternative facilities on the East Arm would have a potential to significantly inipacl tlic vegetation of the area. It is estimated that several thousand acres of vegetation could be dirractly or indirectly affected by these implementation alternatives. It is unlikely that these impacts car1 Lie reduccd to nonsignificance. It is not anticipated that Federally listed threatened or c~nd,itil;crcdspecies will be affected by these alternatives, however, several candidate or BLM species L.O~II

I~nviroiitiiet~l;ilcommitinents for the proposed action and its alternatives will include performing silc,~slvx.ifichotanical surveys during the appropriate time of the year of all construction sites and

I~CWimpict areas in order to gain detailed information of the botanical resources as well as the poh*titial Occurrence of sensitive species. Mitigation measures will be formulated on a sitespecific bask for revegetation as well as avoidance of sensitive species. -

4 - 25 Y.4.1.8.3 Wetlands

'l'tic proposed action and implementation alternatives will not impact any wetland resources.

Y.4.2 All< QUALITY IMI'ACTS

'I'he relocation of 271 personnel to YPG will increase the on-site staff by 13 percent. On-site and of!-site emissions will be increased as a result of increased vehicular traffic, as well as increased wedpons testing on the KFR. Weapons testing is expected to increase by approximately 30 percent while the number of rounds fired is expected to increase by 50 percent (Porter, personal communication, August 1990). Other operations are expected to remain relatively unchanged and no new emissions sources will be added as a result of the realignment.

It is anticipated that most of the new personnel for the mission realignment will be housed off- base. As a worst case scenario it was assumed that all 271 personnel would commute 24 miles each way on a daily basis. Based upon the Air Quality Handbook methodology as discussed in Section 3.2, additional vehicle emissions are calculated as follows:

Carbon monoxide = 25 pounddday Ikuctive organic gases = 2 pounds/day Nitrogen oxides = 10 pounds/day l'arliculate matter = 2 pounds/day

'l'lius, '111 coinmuting vehicle emissions will increase by approximately 15 percent. Based upon the fact tti,rt ,111 of the above parameters, except particulate matter, are below regulatory levels for the Yuma area, no significant adverse impacts are anticipated from other sources. As particulate levels in [tic area already exceed standards, the daily addition of 2 pounds of particulate matter is corisidcrc~da significant impact.

Mitigation measures to reduce the commuter related emissions will include the encouragement ol iix of buses for workers commuting to YPG as well as possible incentives for car pooling and use d V

IIICI~*~M In Ir.illic associatd with the JPG mission transfer. If t1ie.e goals have not been reached, LIicii otlic~incivitives will be provided to assure that the goals are met.

C'onslniction or the various facilities associated with the transfer of the JPG firing mission to YlY; will also result in relatively short-term emissions associated with construction activities. While otticbr pollutnnts will not reach significant levels, dust may produce a significant impadduring this

4 - 26 period. l'liis impict will be reduced to nonsignificant levels through use of water and if necessary, ciivironmcntally approvd dust control chemicals to reduce emissions. Additionally, the areas will be stabilized through use of gravel or other measures after grading and construction to reduce wind erosion afler grading.

Arlillery and mortar weapons and munitions testing are typically performed during daylight hours Monday through Saturday. As this area is accessed over paved roads, dust impacts from increased operations will be minimal. Particulates of DU and beryllium occurs on-site from the testing of these projectiles. Air emissions include smoke produced by propellant and munitions generatid from firing, and particulate matter from the projectiles upon impact. Due to the vast area in which smoke emissions have to dissipate and which the particulates have to land before cncuuntcring any receptors (except those receptors in the immediate vicinity performing the tests) and the extreme mass of uranium, these particulates will settle out of the air before any sensitive recvptors are impacted. As such, no significant air quality impacts are expected due to increased opcr'itions at the KFR.

Sincc the increased emissions associated with the transfer of JPG's mission to YPG will result in only slightly increased emissions and those can be reduced to nonsignificant levels, the implementation of the proposed action will not impact the ability of the area to reach attainment levels on particulates.

The Main Administrative Area includes housing facilities, administrative, support and storage facilities, sewage ponds and a landfill. No testing of military equipment occurs in this area. Storage facilities include above ground storage sites. The materials stored include gasoline, oil, waste oil, lubl-iciinls and pesticides. Even with increased on-base operations, under closed conditions, the slor,ip. of lhcse products is not anticipated to cause significant air quality impacts. An increased odor impact could possibly occur from the additional use of the sewage ponds; however, they are li~(til(tl(11 ii distance from the Main Administrative Area where no receptors are in proximity. Thus, any additional odor impact would be insignificant.

luqilenientation alternatives to the proposed action would be expected to have similar adverse, hut riot significant impacts.

Y.4.3 NOISE IMPACTS

With the proposed mission transfer from JPG weapons testing will be stepped-up considerably. Mob1 of the new personnel (271) will be associated with testing on the Kofa Range. This range typtc~llyoper.ites for eight to ten hours during the day. Monday through Saturday. The hours of

4 - 27 opcrcition are expected to remain the same, however, the number of personnel and number of rounds lircd are expected to increase. Presently, approximately 600,000 manhours are expended ycurly on this range. As currently planned (Wade Porter, personal communication, August 21, IYYO), testing will be increased by approximately 180,000 manhours per year or about 30 percent. Additionally, the number of rounds tested is expected to increase on the order of 50 percent and will be pcrforind in the same time frame. The increase in testing is expected to increase noise levels both within YPG and potentially in the Kofa National Wildlife Refuge.

A recent noise study prepared for WG (USATHEMA,1991) it was determined that noise for the existing and proposed JPG range operations are compatible with the land uses at WG. The inconipatible zone 11 and 111 levels, however, extend beyond the installation boundary at only one location; into the Kofa Game range. These zones are the result of existing YPG range operations, and not due to the addition of JKoperations. The noise study is on file at YPG.

bough no off-site exceedences of the 65 dBA Ldn are predicted by computer modeling (except to the above mentioned Kofa game range), people living near YPG may be annoyed and could complain about the noise environment. The severity of annoyance is typically based upon whether the, person is indoors or outdoors, whether the person is economically dependant on the installation, tlic basic attributes of the noise (Le., intensity, spectral characteristics, duration, repetitions, abruptness of onset and cessation) and the presence of ambient background noise. Further, social survt.ys have shown that other factors such as the degree of interference with current activity, previous community experience with a particular noise, time of day, fear of personal danger association with the noise source, socioeconomic status and educations level, and the extent to which [lie pip~lacrbelieve that the noise can be controlled contribut to the annoyance factor. Though the rang(* of noise levels expected in the Kofa Range impact area is not expected to cause damage claiiiii, it is anticipated to cause a low to moderatae risk of noise compliants from receptors located allting the YI’G southern boundary.

Studies have determined that variations in barometric pressure, temperature and wind velocity with altitude can cause noise events to be inaudible in one instance yet highly annoying in another. ‘l’his phenoinenon, referred to as atmospheric refraction, is caused by the bending of sound waves c.111c(iiic~~trate acoustic energy causing sound levels to be significantly greater. Conversely, these xniti(l WIIVL’S can also be bent upwards so that the acoustic energy of an event may be dissipated intv tliu akmosplicre resulting in a lesser sound level on the ground. A simplified technique has IICI~II J~w4opedby the Explosives Research Group (ERG) to predict these atmospheric refraction coiiililioiis. ‘l‘his technique provides a good approximation of the effects of weather conditions on iioisc’ prop,igation and provides a mitigation measure to abate off-site noise and the resultant recptor

4 - 28 t oiiiol.iiiits. 'l'ht, types of atmospheric conditions conducive to off-site noise transmission are wiiini,irind below.

( iood Conditions Bad Conditions

Clmr skies with billowy cloud Days of steady winds of 5-10 mpg with fornntions, especially during gusts of greater velocities (above 20 mph) warin periods of the year. in the direction of residences in proximity. A rising barometer immediatly following a storm. Clear days on which "layering" of smoke or fog are observed.

Cold, hazy or foggy mornings.

Days following a day when large extremes of temperature (about 20°C) between day and night are noticed.

Generally high barometer readings with low temperatures.

I.ong-term traffic noise concerns from the increased population density at the YPG center primarily on mobile source noise emissions on the major roadways in and around the Main Adniinistrative Area. Regarding vehicle traffic noise, the FHWA Traffic Noise Prediction Model was ruri iisiiig an increase of 13 percent in the number of vehicles on the road (corresponding with a 13

ptwt~ii~increase in personnel) in a one hour time period. The model predicts that this increase in vcliicul.ir traffic will raise the on-site traffic noise level by less than 1 dBA, an imperceptible amount uiiJt.r any but the quietest conditions. As such, even assuming the worst case scenario where every t:IiipIoyc'c' and contractor plus all relocated employees (2,421 total) would be on the same stretch of rod siriiuitancously, no significant noise impact would result. Construction of new facilities on the li,isl Arm will generate additional traffic related noise. While adverse, it is not expected that sii;iiific

With regard to noise impacts to the Kofa game range, numerous studies have demonstrated that various birds may be momentarily startled but will typically return to their preevent behavior. AJdilionally, some species seem totally oblivious to noise events. Though scant information is ~ivciil~ibl~on animal population dynamics, such as return time to equilibrium after an elevated noise

4 - 29 went, the increased noise from the base realignment is not expected to have a significant impact on wildlife.

Y.4.4 HUMAN ENVIRONMENT IMPACTS

Y.4.4.1 Visual and Aesthetic Resources

Implementation of the proposed action will result in the construction of various new buildings and other facilities near the location of existing facilities. Although this may constitute an adverse impact, it is not considered significant since the area is already developed. Furthermore, a significant adverse impact to aesthetics on the Kofa Range due to increased munitions testing is not considered significant since the area is already used for munitions testing. Measures that will p~rtiallymitigate aesthetic impacts will include painting of structures to blend in with the area (e.g., earth tones), use of landscaping and sensitivity in the placement of individual facilities to minimize their impact.

Construction of the East Arm alternative has a potential to create significant impacts to aesthetic resources since it would place buildings and other structures in a generally undeveloped area. No milipition measures would be available to reduce these impacts to nonsignificant levels.

Y.4.4.2 Native American Values

'l'he American Indian Religious Freedom Act (AIRFA) of 1978 requires all Federal agencies to t,ikr. into account the effects of potential undertakings on traditional Native American religious and cultut'il values and practices and, insofar as possible to not adversely affect those values. Sites of Natiw Anicrican significance need not qualify for listing on the National Register of Historic Places tu mcri( protective management. Sites of traditional Native American significance include Native Anwrican sanclified cemeteries, places of worship, religious or ceremonial sites, and sacred shrines; traditional hunting, fishing, and gathering areas; and archeological sites that can be attributed to thw dncestors and/or contain Native American burials. These sites will be better determined by co~i~idt~tionwith representatives from the Cocopah, Yuma, and Colorado River Indian Reservations.

Il,~scdoii preliminary analysis, it does not appear that the proposed action will impact any site of Native Atnerican values since the area is presently used for similar munitions tcsting. Adoption of tli(> ~iiiplciiic~it~tioi\alternatives in the Fast Arm of YPG would have a greater potential to impact thc\c I c.so,onrc'cs.

4 - 30 Y.4.4.3 Archeological/CulturaYHistoricalResources

( hly lwo pcwcnt of lhe YPC (20,429 acres) has been surveyed. Only in the last eight years have sysltmtlic and intensive survey projects been undertaken. These surveys have been limited by the ;ic.wssibility which has been granted and are generally project specific. The paucity of information typicdl of early archeological site record forms reflects a failure to record data such as site size or to provide maps of data reflecting artifact and feature distribution. Much of the mountainous areas of YI'C has not been surveyed. No evaluations or data recovery of the 16 rock shelters or larger camp sites have been made to determine their potential for contribution to the knowledge of YPG archeological sites. It is here, particularly in the potential for stratified remains in rock shelters, that some of the most significant results may be realized (Schaefer 1989a).

130th direct and indirect impacts will be considered in relation to the potential of existing cultural resources. Direct impacts involve the possibility of direct physical damage or disturbance due to intrnsifying artillery activity, disturbance caused by construction, grading of roads, pads, and ground surfaces, placement of utilities, wheeled and tracked vehicle testing, and off-road vehicle dclivily. Indirect impacts may be caused by vandalism.

Surface and subsurface disturbance of the direct impacts listed above could eliminate any surface remains of archeological sites. Since the majority of the recorded sites appear in areas of Uttle depth of dcposit, surficial remains may yield all the information available concerning these sites. Only Ilirw limiled evaluations from surface artifact scatters have resulted in small artifact collections being analyzed (Schaefer 1989a). If fragile surficial remains and features are altered before rccordalion, this will decrease or destroy the value of the site as a potential source of knowledge. [:(~ii~~iiiiiii~~ioiiby UXO could preclude the possibility of retrieving pertinent data from archeological silk. as well as eliminate the possibitity of accurate radiocarbon dating.

Vandalism occurs in the form of unauthorized digging or collection of artifacts. This activity could increase with the presence of more personnel in the area. Historic sites are especially vuliic*r,ihle to disturbance by unauthorized collection of artifacts since the remains of a historic site trior(' rc~<.o~;iii;..ableto the untrained eye.

A historic propertics survey of Army-owned stmctures on YPG was conducted in 1984. This sti~tyiii(iicakd that there were no significant structures present on the installation since they were coiisli-wl~dposl 1950 and do not meet the age criterion for listing in the National Register of 1 lisliiric. I'liices. 'l'liere are 31 recognized historic sites primarily associated with mining activities. A 1 listoric I'I~wrvati~iiiPlan on YPG is in progress to aide in the management of properties, both historic ,id prehistoric, that may be eligible for inclusion in the National Register of Historic Places.

4 - 31 I Iiic, plCiiiwill include procedures for the location, identification, evaluation, and treatment of eligible properties on the YPG. Coordination has begun with the Arizona SHPO on the proposed action.

Surface disturbing activity associated with the implementation alternative in the East Arm of YIY; could impact the 44 sites recorded in 1983 by Mann. Mann’s work in the area was limited and the exact amount surveyed is estimated at 1,280 acres. There has been little or no (40 percent disturbance in areas) historic and modem ground disturbance in this area. Resources may be little disturbed or intact in this area because of its isolation and little utilization in the past. The East Arm region is likely to yield significant information concerning YPG prehistory. A high number of sites havc been recorded in ratio to the small area that has been surveyed. Partially responsible for this statistic arc1 the flaws of the predictive model testing employed by Mann during his survey. The types of sites recorded by this project do suggest that the East Arm region has a high potential for containing numerous significant cultural resources. The East Arm does contain one of the most significant cultural resources. The area around the White Tanks site is currently being proposed as a National Icegister District, as well as two other areas. This impact is especially significant in that the area is now relatively uncontaminated by UXO. Mitigation may not reduce impact to nonsignificant levels.

Archeological surveys will be conducted at all proposed construction sites. All sites found during the surveys will be evaluated as to National Register eligibility. Those found eligible will be avoided or mitigated in accordance with Section 106 and the PA (Appendix C). Other measures being taken to comply with the NHPA are desaibed in Section 2.2.4.

Y.4.4.4 Zoning and Political Boundaries

No diaii~;c~sin zoning or political boundaries are associated with the implementation of the prq)[~wJaction. A Direct Fire Range located south of Pole Line Road, will require permission from ~hcIkder~I Aviation Administration (FAA) for the establishment of a controlled firing area from pound lcvel to 3,000 feet. This has been negotiated with the FAA. Since YPG would be responsible to assure that no aircraft are within 5 miles of this zone when firing operations are underway, no sipiificarit impact to aircraft operation are anticipated.

Ai1 liast Arm alternative would not result in the changes of any political boundaries or affect current zoning.

4 - 32 Y.4.1.5 Strcioeconomic Characteristics

'l'liis section analyzes the potential socioeconomic impacts associated with the transfer of up to 271 civilian personnel positions from JPG to YPG. As with JPG analysis, the primary source of this inlormation is from the SEA Report prepared by the IWR. Economic modeling was conducted using the CIXL EIFS in order to quantify the projected economic impacts. Table Y.4.4-1 summarizes the projected economic, population, and housing changes associated with the proposed realignment. 'l'hcse changes are discussed in the following subsections.

Y.4.4.5.1 Population

Implementation of the proposed realignment action will result in the transfer of 271 civilian pc.rsoiinel positions to YPG. This change would result in the projected addition of 845 people to the rlreLi This change would amount to an approximately 0.4 percent increase to the two county rc1;ional population and approximately 1 percent gain to the Yuma County population assuming that all would live in that county. Since these transfers are all civilian, it is assumed that they would live off-post in Yuma or the surrounding area. Due to the small population increase that this would represent, it is not anticipated to represent a significant impact. It should be noted that impncts for the East Arm alternatives would be the same as the proposed action on a regional basis. Implc~mcntationof this alternative may impact the small communities such as Wellton and Mohawk loc.itcd cast of Yuma.

Y.4.4.5.2 Regional Economic Activity

l'r~irto the end of FY94, construction and other expenditures on the post would be expected to l~avt,'I 4mrt term beneficial impact. An estimate of these potential benefits are provided in Table Y 4 4-2 It should be noted that these short term benefits will cease once the realignment and r~w~ti

l'rcitislc~rof JIC testing activities to YPG is expected to directly create 271 jobs in the area and is propvt(d to incrc'ise employment by 575 person years annually. This will be a beneficial impnct to tlic, t (iiiiiiiiinity.

'I'lw addition of personnel and functions at YPG is also expected to contribute approximately $7.05 million ,innually to the regional economy from direct wages and an additional $12.8 million in dirct.1 cxpctiditurcs annually to the region. On a regional scale, regional income is expected to inct~tmi~by nearly $11 million and regional sales volume by $32.3 million. While this represents 1.0 per~'cntand 4.4 percent increases in regional income respectively, this increase is not considered

4 - 33 Table Y.4.4-1 Summary of cconomic impacts at YK realignment associatcd with JPG closure.

Yuina I’rovinr Ground lmmcts

I’crsonncl Changes: Civilian

Ilircrt Wap~: Civilian +$8,009,244 l’o\t lixpcndilurcs +$12,764,wO

C‘onslruction Expcnditures +$82,22O,ooo

Ow-time Expenditurn $30,400,000

%wnd Jobs (workers and dependents): Direct +I8 Indirect -+I92 Total +216 Percent Regional l

S,tlrs Vlllunlc +$32320,000 4.4% limployincnt (person years) 575 1.6% IIICOI111~ 1.O% l’opulation 0.4% Nutnlwr (I( School Childrcn I loitsing demand: I

N( Yl’li: listitnates arc subjcct to change.

4 -34 'I'.iblc*Y .4.4-2. Estimatcd annual economic benefits at Yuma Proving Ground during the implementation of thc rcalignmcnt activities.

Construction Ow limc Expenditures Expcnditurcs Total (mllllons) (millions) (millions) l:oiir-ycar amount $82.2 $50.0 5132.2

Sdcs Volumc $25.2 516.2 $41.4

Ihploymcnt 434 152 586 (prwn ycars)

4 - 35 significant since it lies within the expected bounds of the normal economic cycles of the area. It is also expected that there will be a net economic gain to the local governments. This would be due to both increased population and revenues from increased regional sales volume.

I1 sliould be nottd that the East Arm alternatives to the proposed action would be expected to Iiavc- similar impiicls to the proposed action with the exception of the short-term construction impacts. Construction of new facilities would be expected to create greater economic benefits since the construction would be a greater amount. This would be for the period of construction only.

Y.4.4.5.3 Housing

Uascd on the anticipated characteristics of those personnel moving into the area hom JPG, it is projected that there will be an increased demand for 271 off-post housing units including 101 rental units and 170 owner occupied units. Based on the existing housing market, it appears that the market can readily accept such an increase with no impact. Since the rental market is sometimes tight in the winter months, those moving to the Yuma area during that time of year could expc,rience difficulties in obtaining rental units. This potential significant impact can be mitigated to insignificant levels through scheduling transfers during the late spring, early summer, or early fall nion t lis.

'I'licw is a potential that the construction of the new Jeffersonville facility on the East Arm and associatcd access road could induce personnel to live east of Yuma in such communities as Wellton. 'l'hcw could be a significant impact on the housing supply on these communities since housing is currcnlly limitcd.

Y.4.4.5.4 Schools

11 is CLslirnated that new personnel will contribute an estimated 156 new school children to the arw schools. Almost all of these school children would be expected to attend off-post schools. Due to tl~chf.id that the students would attend several districts and individual schools in those districts plus tlit, schools would be eligible for PL-874 funds, no significant impact to area schools are ,I 111 ic i pi1cd

A\ dtvrilicd under the housing section for the Jeffersonville alternative, if a significant number of pnoiincl would live in the communities east of Yuma, there is a potential that the small rural xh)oI districts could be significantly impacted by this alternative.

4 - 36 Y.4.4.5.5 Land Use

Iniplementation of the proposed action is not anticipated to create significant land use impacts since testing activities are presently occurring within these areas. Facilities such as ammunition stor.lge, handling, and testing would be constructed adjacent to existing facilities. Construction of altcmutive facilities in the East Arm may have the potential to create significant land use. impacts in that the areas are not currently used for munitions testing. Additionally, off-site land use impacts may occur in areas south of the Jeffersonville area due to demand for housing in the area.

Y.4.4.5.6 Health Care

Mcdical facilities for base personnel on YPG are limited and are adequate only for routine treatment and procedures. Emergency response for serious illnesses and injuries also are limited. The additional mission personnel will strain the existing YEfacilities and medical staff, resulting in an idverse impact. Provision of addition medical personal will reduce this impact to nonsignificant Icwels. Dental facilities also will be adversely impacted by the influx of personnel. Expansion of facilities and staff will reduce the impacts to nonsignificance.

If the proposed East Arm alternative is implemented, new health care facilities will need to be constructed at the proposed Jeffersonville site. Medical, emergency, and dental facilities and an adcquate staff will be required to serve the additional base personnel.

It is expected that the total number of additional personnel on-base will be 271 persons. Since it is lihcly that the civilian personnel and their dependents (approximately 845 persons total) will be Irocrs(d off-bdsc, a local impact to the surrounding city/county medical services will occur. The inpict to thc rncdical and dental facilities off-base (primarily in Yuma) will be incremental and I nonsil;nificant. It is anticipated that existing health care services available in Yuma will be adequate lo stwe tlic additional population. 'LL 0 :I1 Y.4.4.5.7 I'ublic Safety

ic;

'l'lie existing fire protection equipment, and firefighting water supplies around populated areas, 111, (.ouplcd with the sparse vegetation outside the Main Administrative Area, are adequate to limit the (icc.iiritwc.LB OIond control fires within the areas where most personnel are located. The transfer of 1'1 pcrs~innclIrom j1.G will most likely require additional installation facilities and will increase testing opc-rqitions,resulting in a greater potential for fires to occur. The impact of additional facilities and U ll2 . 'So,, , 4 - 37

dl Iwrsoiincl will be incremental to the current level of fire protection at YE. Due to the nature of the opcratioiis conducted at YPC and the proposed expansion of activities, there is a potential need for addiiional lire and rescue equipment and personnel. Additional equipment, including a fire engine, Jnd staff will be provided.

If the East Arm alternative is implemented, new fire fighting facilities to serve the area will be necessary. The eastern portion of the site contains slightly more vegetation, particularly in washes, 'ind may result in a higher fire potential than the remaining parts of the installation. Provision of adc-quale fire protection facilities and staff and compliance with building requirements and safety programs pertinent to fire prevention will reduce the impacts to nonsignificant.

'l'lic inipact to local, county, and regional fire protection facilities will be incremental and Iionsignificanl. No mitigation is proposed.

('onlaminated Areas

lixisting impact zones in the Kofa Range will continue to receive ordnance from testing activities. Implcmcntation of the proposed project will increase the quantities of ordnance placed on the site, and will further aggravate a significant adverse impact. Impacts to these areas will remain significant unless testing activities are reduced or completely stopped and long-term cleanup is initiated. I'recautions are required to minimize the exposure of personnel to UXO or radioactivity in tlir, arms where the DU projectiles are tested. Potential impacts to personnel are reduced by the protective clothing and special training provided to military and civilian personnel permitted into these areas. Proper marking of contaminated areas and providing active (guards) or passive (tciicing:) sccurity of the areas has reduced exposure possibilities. In the Final Environmental Awwtiiont for the United States Armv Yuma Proving Ground (1987), it was determined from civdildblc lilcrature sources that hazardous materials are being stored and disposed of in a safe miiii(*r. Also, following the USEPA and Arizona Department of Environmental Quality inspections (11 I YHY, improvcments in storage, transport, and disposal methods in compliance with Federal, state,

,ind Iii~rlrt!gulations had been occurring. An increase in personnel and operations will add to the iircl titii;c'iiicmt workload at YPG to assure proper storage and waste disposal practices are riiiplrinciitcd. As discussed in Swtion Y.4.4.6, a recycling and waste minimization program has been di*v(4opid and implemented. Leak testing is being regularly performed. Since these mitigation niclisures have been implemented, impacts from hazardous materials will be reduced to ii(itisi~;tii~ic

4 - 38 Iinplenicntation of the alternative on the East Arm will result in ordnance contamination in an lir(w r(4,itivc.ly free of contamination. There will also be the requirement for expansion of waste ti~~~i~lliti~:pr(i(xYfures.

Y.4.4.5.8 Traffic and Transportation

I lighway 95 serves as teh principal access arterial to YE. This roadway is primarily a two-lane narrow paved highway that is heavily used by farm vehicles, recreational vehicles and similar special uses in addition to YPG-related traffic. Numerous fatalities have occurred on the roadway. May have been due to collisions with farm equipment and hitting of large animals including wild horses, burros and deer. Realignment of JPG activities to YPG will result in up to an additional 542 trips per day to or from YPG associated with personnel commuting to work This is a potentially significant impact due to the already hazardous conditions on Highway 95 in the morning and late afternooir commuting periods. YPG plans to reduce this potential impact by encouraging an cxpandcd bus commuting program as well as encouraging van and car pools. In addition, YPG pcrs(innel will work with other local agencies to work for solutions to the hazardous conditions. I'cissiblc regional solutions could include widening of all or portions of Highway 95 as well as fencing potential sections of the roadway to reduce the potential for collisions with large animals. I;urlhcrmore, YPG will not create additional water sources for wildlife without consultation with agencies including the USFWS, BLM, and Arizona Department of Game and Fish.

Upgrading the road network is a continual process due to the number of gravel/unimproved roads, tlic extensive use by military vehicles, and the periodic damage due to heavy rains. The level

(if ,it~eritiongiven to the internal circulation system is appropriate for the existing missions. As upcr,itions expand, additional roads may be required. Road degradation could occur during wiistruction of additional facilities, however, these impacts will be temporary. Overall, no significant impacts are anticipated as a result of the proposed action. Roads will be installed in conlormance with all pertinent Army regulations and standards. No other mitigation is proposed.

liiii)l~,iii(,iit'itioii of the proposed action or other alternatives will result in a substantial increase in th18 .iminriit of munitions being transportid to YI'G primarily via truck. Although these iiiiiiii[iiitilr will bc transported in conformance with Department of Transportation (DOT) and Army rc~;(iI~itioiis,tlicw is still an increased potential for accidents involving trucks carrying ammunition. 'l'liih wwld constitute a potentially significant impact that cannot be reduced to nonsignificant levels. 'I'lw cxistiirg rail transportation system is considered adequate to serve YPG mission activities and milit'iry personnel/family needs. Additional goods and equipment will be required as the popiil~rti~iirdnd operations at YPG expand. Railroad and shipment facilities are expected to be

4 - 39 adequate to serve any supply needs. No ordnance is transported by rail. No adverse impacts are nii(icipakd, therefore, no mitigation is proposed.

I ,o(,,il .iir traiwportation outside of YPG is adequate to serve the additional civilian pcrsonnel livtni; off iIw basc. Any impacts to air transportation and traffic associated with the proposed projt~twill be incremental and nonsignificant. No mitigation is proposed. Impacts ,to airspace sicccs> 'ire discusscd in Section Y.4.4.4.

Y.4.4.5.9 Wastewater Disposal

Implementation of the proposed project or East Arm alternative will increase sewage generation on YI'G by approximately 27,100 gallons per day. This is based on a generation rate of 100 gallons per person per day for the 271 additional personnel that will work on-base. The current sewage lagoon capacities are sufficient to handle the additional wastewater generated by the project. Inipncts to the system are expected to be nonsignificant. The realignment will also have minimal impacts to the wastewater treatment facilities in the surrounding towns as the maprity of the incoming civilian personnel and defendants will be housed off-post. The wastewater treatment facilities in the surrounding area are expected to be sufficient to process any additional wastewater dischargc. The dry climate at YPG is generally suitable for the use of sewage cvaporaIion/infiltration l3gOOW for wastewater treatment. No significant impact to the sewage systcni on base is anticipated since additional wastewater use projected by the realignment is within tliv <..\pacityof the system.

Y.4.4.5.70 Solid Waste Disposal

A trinporary increase in solid waste is expected during realignment from the disposal of utiw~ntcdgoods and packing material during personnel movement and from construction and rcniivaticrn activities. No significant impacts are expected from this increase. After completion of Ihc transfer and realignment, a slight increase in solid waste should occur due to the increase in pcwmnc4 This impact is not considered significant, although it will reduce the life expectancy of tlrv I.inrlfill liy several months. Increased solid waste generation to the local and regional disposal .;II(.siitur YI'G is also exptiled from the additional civilian personnel and dependents residing in LIu. ~iirI~itiii~iingareas. This is no1 expected to significantly impact the lifcspan of these facilities.

Y .4.4.5:11 Necreation

Miiior iinpcts to rcrreational resources are anticipated with an increase in base population. 'I'licsc inp>ctswill be mitigated by continued maintenance and development by YPG. Recreational

4 - 40 rcsoiirces are currently provided by YPG to meet the demands of military personnel and their f;iniilic~s. These facilities will be expanded and/or upgraded as needed to provide continued rccrc!aticriiaI and leisure opportunities for residents. Where recreational resources are not provided on tlic installation itself, they are provided in Yuma and La Paz Counties. No significant impacts to loc.il and regional recreation resources are anticipated by the addition of new personnel and their families. l'herefore, no mitigation is required.

Y.4.4.5.12 Utilities

Water Supply

Lhnestic and nondomestic water supplies at YPG are currently adequate following installation of the water treatment facility in February 1986. Drinking water is now supplied to inhabitants of YI'C; via groundwater wells with purification at the water treatment facility. Water supply for various other domestic uses, as well as industrial uses (mission activities), remains adequate for YPG inhabitants and military personnel. Drinking water for mission activities in remote areas will continue to be supplied via bottled water.

Water supply at YPG specifically designated for fire flow currently meets existing requirements. Fire hydrants located at the Laguna Army Airfield (high fire risk area) are placed approximately 50 feet apart within the fuel storage areas. Fire hydrants within the Main Administrative Area have beinn improved with implementation of the new water supply system and treatment facility. Hydrants are color-coded to distinguish hose size. Both the Mobility Test Area and the Laguna Artily Airfield have interconnecting fire flow systems. Thus, the existing fire flow and water supply system is adcquate for emergency purposes. No adverse impacts from the proposed increase in pcw)nncl and testing operations is anticipated. If the East Arm alternative is implemented, ddition'il facilities will be required.

'I'hc crncq;y supply to YPC is considered adequate for existing mission activities. While .i~lditiiiii.il personnel and expansion of operations will increase energy consumption at YPG, the cxistiiig system will be sufficient to meet the increased energy needs. Additional supply lines to nc'w lacilitics can easily be installed as needed. Recent upgrading at Substation C and use of energy conxwation features in building design have made energy consumption at YEmore efficient. No sigriific,iiit impacts from the proposed project or alternatives are anticipated. Minor impacts from incrcwcd consumption can be mitigated through use of conservation programs. These measures

4 - 41 Includc: use of energy efficient heating systems, proper building insulation, regulation of heater and air conditioning thermostats, turning lights off when not in use, and use of energy efficient lighting.

Y.4.4.6 Hazardous Materialsmaste

YI'C currently stores, uses, and/or generates hazardous materials/wastes in the form of b~ttc~les,cleaning and degreasing solvents, various types of oils, fuels and acids, antifreeze, photographic chemicals, hydraulic fluids, paints and thinners, PCB transformers, compressed gas cylinders, munitions and propellants, and DU and beryllium. The relocation of additional personnel and lcsting missions from JPG to YPG will add additional quantities of some of these items. Testing at the Kofa Range is expected to increase by approximately 30 percent while the number of rounds teskd IS expected to increase by approximately 50 percent.

At the time of the preparation of the document issued by Camp Dresser and McKee (1988), many environmentally unacceptable practices were in the process of being rectified. Mitigation measures have included the reuse or recycling of all possible waste products, the proper storage of 55-galk)ri drums on proper platforms, the retraining of personnel in proper waste management pr'icticrs, and a concerted effort to remove all contaminated soils and materials as tunds are appropriated. Additionally, all storage tanks are being replaced with doublewall fiberglass tanks with leak detcTtors as required by Army policy.

In rcgards to ordnance, all new personnel who are to deal with these items are thoroughly trained in their applications as well as their potential dangers. Additionally, those personnel which deal dircctly with DU and beryllium are trained in their use and dangers and are monitored with rcpulcir physical check-ups with special emphasis on uranium and beryllium poisoning. Personnel exposcd Lo dust on the tank automotive portions of the firing ranges are trained in the proper use of rcspraLurs and protective clothing. Those personnel assigned to collect DU or beryllium, or work will1 hcizardous materials associated with ordnance management and disposal undergo formal or on tlic 101, training as required. Finally, acceptance testing is becoming more efficient requiring fewer personnel and less equipment. Operations are being integrated into the research and development arcas. lilliciency is being carried over to include the operations that produce air emissions and

W'lSl~~S.

With respect tu asbestos, the material will be left in-place unless a building is demolished or uriJci.):~ic~srctioviiticiri. As little of the asbestos is friable and that which is friable is typically used lor pip, insulation with little chance to become airborne, the material is removed and ordinary nuiiikniince occurs on a facility as an action under the National Emission Standards for Hazardous Air l'ollutaiits. .

4 - 42 (;ivcii that these mitigation measures are currently being implemented, and any additional hihirr

An amendment to YPG's NRC license for testing of Depleted Uranium Penetrator Rounds will be required. YPG will be testing these items at a site called the Direct Fire Range to be located south of the I'ole Line Road. License amendments will require the use of a DU catch facility which receives or captures the DU round after it has been shot. This is done in order to maximize DU recovery and minimize adverse environmental problems. Additionally, NRC will require an updated environmental radiological monitoring plan for environmental quality and strict accountability to iissure environmental compliance.

4.5 UNAVOIDABLE ADVERSE EFFECTS

111~~closure of JPG will cause unavoidable adverse effects on socioeconomic resources. The closiirc will result in the elimination or out-migration of approximately 421 personnel, and a 1,234 peimii decrease in regional population. This would result in a total decrease in regional sales volunie of approximately $48 million, a decrease in regional employment of 940 person-years, and a decrease in regional income of approximately $17 million.

Minor short-term adverse socioeconomic impacts are expected during the adjustment period lollowing the realignment action at YPG. Unavoidable adverse effects of the realignment of JPG to Y I'C ; include additional generation of hazardous and toxic materials, the increased transportation activity, increased noise levels from munitions testing, and potential biological and cultural resource iiiiprt5

4.6 Sl~OI~I-TEI~MUSES OF THE HUMAN ENVIRONMENT AND THE MAINTENANCE AND EN1 IANCEMENT OF LONG-TERM PRODUCTIVITY

111 .iii'ilymig the relationship between short-term uses of the environment and long-term prwiuc tivity, trade-off is posed between those benefits which would be accrued from the closure .in

'Hit one-lime expenditures of energy for the movement of personnel and equipment for the cmstriii.tion of facilities at YFG may result in long-term energy savings by increasing energy vlliwncy and overall productivity as a result of consolidating operations. Energy conservation shcnild increase due to the use of the most energy efficient design possible for new construction.

4 - 43 A rcwlt d the closure of JPC will be reduced annual on-post expenditures for maintenance and onj;oiiij; iniprovements/operations. Although local economic activity will be reduced at JPG, iiiili~,iryoperations should become more efficient over the long-term.

'l'hc closure of JPC will eliminate the risk of additional hazardous materials being generated, rihscul, or accidentally spilled. Since the Army will retain JPG property in a caretaker status, the Ariiiy will comply with existing permit requirements to close ,-the RCRA regulated open burning/open detonation units, USTs and submit a decommissioning plan to NRC for the DU liccnsc.

Construction of facilities at YPG, required to meet realignment needs, will render these areas unavailable for alternative Army use. Disturbances to the local ecosystems will be caused by cotislruclion of new support facilities at YPG. This action will provide for long-term use of the land.

Implc~mentationof the East Arm alternative will result in potential impacts to wildlife resources to cultural resources. There will also be increased noise levels in the area due to increased Icsling rcquirements.

I(caligntncnt at YPG will result in the increase of hazardous materials uses. There is also a pokiitial for increased contamination of UXO. Due to the location of munition plants, additional Lransportalion of munitions will be required. This would increase the likelihood of on-highway ~cident

4.7 IRI

C'lowrc of Jl'G will not result in any further commitment of resources because the JPG property Ii,itf ,iln*,idybeen withdrawn from the public domain. The major types of resources which would be directly committed through the construction and operation of the JPG testing function at YPG inchidv c clpital, energy, land, water, and unsalvageable materials.

I IN' commitment of capital expenditures and human resources associated with the realignment will IIC> irrc-tricvablc, but is considered beneficial because money would be introduced into the Yuma IocciI ~~cotiomy.Consolidation of operations is projected to produce a long-term savings.

I(iicrl;y costs of the transfer of personnel could include additional fuel to meet the projected iiicrc.isc in clcctricity demands for air conditioning and other uses at YPG. The transfer of personnel Lilsowill require the commitment of fuel for transportation and construction (new facilities and/or thc riw)vatioii of existing facilities). These resources would be nonrecoverable. .

4 - 44 Use of the existing property within the boundaries of the YPG will not result in additional loss of public domain land use because the proving ground is already withdrawn from public domain as a munitions testing facility. The resources committed to realignment activities at YPG could be limited if the facilities are sited in previously disturbed areas such as the Kofa Range. Disturbance to the Eastern Arm of YI’G would have the potential to cause the irretrievable loss of biological and cultural resources. In addition, contamination of the eastern and western amis currently at lower levels than at the Kofa Range. Chemical release associated with cracked UXO will be less at YPG than currently at JPC, due to the lower potential for migration (DU is not soluble in water). As YPG opcrales, additional hazardous waste will be generated and disposed of according to U.S.Army and othcr Federal and state guidelines.

Water resources at YPG will be committed in the form of withdrawals for use. All of this resource would not be lost since a portion of the water would be recovered through the evaporation-precipitation cycle, or through percolation.

4 - 45 CHAPTER 5 - CONSULTATION, COORDINATlON, AND REVIEW

5.1 LlJIBLIC INVOLVEMENT

I lic Department of the Army published on May 8, 1989 a Notice of Intent in the Federal Register to prepare an EIS for the closure of JPG and the realignment to Yuma Proving Ground. Public scoping meclings were held at Madison, Indiana and Yuma, Arizona. Transcripts of both public scoping meetings are on file at the Office of the District Engineer, Corps of Engineers Louisville District. A summary of concerns, and a list of agencies participating in the scoping meeting are provided in the scrtions that follow.

5.1.1 JI'G Scoping Concerns

'l'lie public scoping meeting to gather information and concerns from the public regarding the closure of JPC was held on June 8,1989, at Madison Consolidated High School, Madison, Indiana. Fifty- eight registered persons attended the meeting. Twelve persons spoke and eight exhibits were submitted for entry into the record. lssues and concerns expressed at the meeting primarily dealt with the following:

l'he amount of exploded and unexploded ordnance over much of JIG,the classification of such materials as hazardous waste, the scope and cost of cleanup and restoration, potential cleanup funding sources, cleanup responsibility, cleanup time frames, the impact of cleanup on the environment, the impact on future uses of the land and potential liability problems, and the separation of cleanup actions from closure;

0Llic.r types of hazardous, toxic, and solid waste use and disposal areas on the installation such as licrbicides, paints, solvents, oils, solid waste, etc. and its impact on the environment and Ititurc. use potential;

- I low thc surplus JPG real estate eventually will be managed, disposed of and reused once the inbtallation is closed, given the current condition of the land and how the public will be involved iii this process;

'fhe socioeconomic impact of closure on surrounding local communities;

l'lic potential for the presence of rare and endangered species on the installation; .

5-1 I'otential for JPG to become an "attractive nuisance" after closure occurs due to the abundance of natural and scenic resources;

Deer overpopulation and its impact on local agricultural areas when management programs end due to closure; and

'i'lie unique natural setting and ecological resources of JPC as compared with surrounding land uses in the area.

Interested agencies and organizations represented at the meeting included the following:

Offices of Senator Richard Lugar and Dan Coates; Office of Congressman Lee Hamilton; Indiana Department of Environmental Management (IDEM); City of Madison, Indiana, Madison lndustrial Development Corporation (MIDCOR). Hoosier Environmental Council; and Jl'C Survival Committee.

Tlirec letters were received subsequent to the meeting expressing concerns regarding JPG's closure and subscquent reuse:

Congressional Representative Lee Hamilton of Indiana stated that he is still confused about how tlic Army estimated cleanup costs, as well as the responsibility for cleanup and closure. He requested khat the Army identify specific closure, cleanup, and realignment responsibilities.

Region 5 Environmental Review Branch, U. S. Environmental Protection Agency (USEPA) requested a detailed and thorough environmental investigation of the proposed action and a mitigation plan for anticipated significant impacts and potential hazards, including but not liinitd to: unexploded munitions, hazardous/toxic/solid waste cleanup and management; the potential of new ordnance and hazardous/toxic substance/waste contamination at YPG; ground and surface water hydrology; impact on seismic activity at YPG; threatened or endangered species; wetlands; wilderness areas; significant agricultural lands; airquality; water quality; noise and vibration; the relationship and consistency of local planning activities with the proposed .\ction; an assessment of anticipated impacts under the range of various implementation ,iltcrnatives such as installation cleanup/restoration and alternative future land uses; and that llic "no action" alternative be considered in the EIS even though USEPA recognizes that P.L. 100-

5-2 536 (Section 204. c.2.B.) exempts DOD from considering alternatives other than the proposed aclion.

‘I he Indiana Department of Environmental Management (IDEM) submitted a letter outlining primary issues IDEM requests be included in the EIS. These include a thorough evaluation of widespread ordnance contamination with respect to future land use options, cleanup technologies and processes, and potential liabilities of future land owners and managers; public safety hazards posed by ordnance contamination and the potential for additional site security measures; the impact closure and cleanup will have on natural resources which should include complete and accurate inventories of plant and animal populations (including rare/endangered species); and the impact of a variety of pollutants and contaminants used at JPG on future land use options and the potential for future liability actions.

5.1.2 YI’G Scoping Concerns

The public scoping meeting for the mission realignment of YPG was held at the Stardust Resorts Motel in Yuma on June 26,1989 at 700 p.m. Forty-nine people attended the meeting. Eight attendees spoke. Issues and concerns expressed at the meeting dealt with the following:

The current pristine condition of the locale;

Archeological relics and Native American artifacts on the East Range, particularly the White Tanks area;

I’otvntial loss of use of the land for recreational pursuits, especially hunting; and,

I’otcntial effects, e.g., increased traffic burden on roads, on residents of two communities near a proposcul siting, etc.

Writkm testimony, received after the meeting, expressed these concerns:

Shte I iistoric Preservation Officer (SHPO) Archeologist and Compliance Coordinator noted that no properties within YPG are currently listed on the National Register; however, many cultural rcwurces are potentially eligible including: ephemeral remains of nomadic hunters and gatherers; intaglios, macroflaking loci; prehistoric and historic trails; and other important reseurces.

5-3 Wcllton-Mohawk lmgation and Drainage District was primarily concerned with the effect proposed activity will have on the district and the impact increased people traversing the range will have on housing, schools, public roads, etc.

‘l’hc US. Department of Interior Fish and Wildlife Service was concerned about notification of incrtings and polential impacts on Imperial and Kofa National Wildlife Refuges.

5.2 LIST 01: CONTACTS

5.2.1 Jrfferson Proving Ground

-Date Person Contacted Purwse

LOCAL Ihnovcr College 9/6/89 Dr. Daryl Kams Reptiles, amphi- Assistant Professor bians and Biology Department natural resources

9/6/89 Dr. J. Dan Webster Birds and listed Professor of Biology species emeritus

9/8/89 Paul McMillan Plant list Assistant Professor Botany Department

L>cl’du w Univcrsity, 10/89 Dr. James Cooper Historical Record C reeiicds t IC, Indiana Professor of History bridges

City ol Madison -- William Dossey Socioeconomic Special Projects data Administrator

_____ Marlene Croumens Zoning Informa tion

5-4 l

Jcnnings County Planning Mane Garrity Planning /Zoning <’oininission Data

]clfcrson County Planning __ Representative Planning / Zoning Commission data

STATE

Uept. of Environmental 9/26/89 loe Foyst Air quality Management, Office of Air Management

Ikp of linvironmental 9/18/89 Steve Lengerich Air quality Management

Ikpt. of linvironmental 9/21/89 Harry Williams Air quality M,inagcincnt, Director Offlc(i ol Technical Assistance

I)(*pl of Environmental 10/21/89 Bany A. Smith Climatological M‘I n,igenicnt Environmental Scientist Data Olfi( c* (if Air Management

iI(-pt uf Ihvironmental 10/26/89 Paul Kluxton Water quality M.rii,rl;~weiit,Enforcement Division

!+,,it. 1k1~1rdol Iiealth 9/21 /89 Dave Zell Air quality Air I’olhition Control Division Engineer

9/26/89 Jay Rodia Air quality Attorney

Iiidi.rii.i Ikpt. of Natural 9/6/89 Endangered I11 ‘InJ Wildlife Service of concPm

5-5 Itidiiiiiii I Icritage Program 10/16/89 Michelle Martin Natural areas Ilivision of Nalural Data Manager and listed I’rcscrvcs, IN DNR species

Iridi;ina Ilcpt. of Natural 9/13/89 Parks and Ilesorrrccs, Division of State Parks recreation

Indiana Dept. of Natural 5/7/90 Tom Lauer Aquatic I(csori rces John Winters Resources

9/26/89 Gary Lake Paleontology Paleontology Dept. information

Indiana Ikpt. of 9/26/89 Wayne Brattain Groundwater linvironincntal Management, Public Water Supply

Office of Water Mgmt.,; 9/26/89 Mark Stanifer Sewage NI’INS Permits treatment

Indisiii.i Ilept. of Natural 9/6/89 Jim Mohow Cultural Ilcscwrccs, Division of Historic State Historic Resources

1’1 cww.itioii and Archaeology Preservation Office

9/18/89 Gary Stegner Noise Data Public Relations Office

9/89 Kaushik N. Joshi Informa tion 10/89 Environmental. including Coordinator, Directorate permits, of Engineering and hazardous waste Housing regulations

5-6 1 O/ 10/89 Ken Knouf Timbering Natural Resources records, natural Manager resources, cultural values

8/2/89 Mike Moore 0rdna.nce and Management Control hazardous mat.

8/3/89 Jim Fritsche Ou t-briefing Director of Engineering and Housing

_- John Russell Master Plans Housing and Planning Manager

_- Leonard Shaffer Migration Plan Director of Resource Management

9/21 /89 Charles P. Watts Satellite photos LTC,OD Director of Material testing

U.S. Army Corps of Bertha Miller Reuse l

_-__ Lee Taylor Reuse Administra tor alternatives

9/18/89 Dr. Ccwrge Luz Noise Data

9/26/89 Dr. J. Louis Noise Data

US. Army 'I'cst and Michael Early Migration Plan

I (VJ I (I ,ilion Command (TECOM) AMSTE-PL .

5-7 U.S Army I3RK Real ____.Gary Patterson Reuse listate Office Chief alternatives

US. Fish and Wildlife 10/2/69 Dave Hudak Species of Service Supervisor concern

5/19/90 Ron Erickson Wetland Regional Wetlands mapping Coordinator

U.S. WA, Region V 9/26/89 Milo Anderson Water Quality John Delassandro

US. Dept. of Interior 5/8/90 J. Medlend Wild and Scenic Naiiorial Park Service Rivers

Indiana National Guard -- Joseph Heck Reuse State Contracts Officer alternatives

Ix)I) Oflice of Economic Anthony Harper Reuse Adjustment Coordinator alternatives

Arthur H. Osgood, Jr. Reuse COL, EN Altema tives

('cwtr.r for American 10/2/89 Kenneth Famsworth Cultural ArcIi,icoIogy: Contract Arch. Archeologist resources l'rot;rcini, Karnpsville, Illinois

David Daghin Reuse Chairman alternatives

Ellen Davis/ Socioeconomic Linda Heitz data

5-8 Jan Schuler Socioeconomic data

JcffcrsonCwnty Employment Peggy Hans Socioeconomic and Training Center data

Madison lndustrial ManeChristine Spence Socioeconomic IXvelopnient Corporation Director data

Madison Chamber of Karen Follett Socioeconomic Commerce Director data

Jcnnings County -- Jennifer Ertel Socioeconomic industrial I>evclopment Corp Director data

Madison Courier Newspaper -- Don R. Wallis Socioeconomic Publisher and JPG Closure data

_- Socioeconomic and JPG Closure information

5.2.2 Yunia I'roviw Ground

-Date Person Contacted Purpose

Betty Davenport Vegetation Pat Cnllahan

Jody htiiner Installations Landscape Specialist

6/21 190 Fred Stone Schools

5-9 Arizona Commission of Larry Richards Vegetation Agriculture and Horticulture Native Plant Specialist

Arizona

Bruce Palmer Natural Diversity Database

_- William E. Werner Biology Habitat Evaluation Specialist

-- Richard Remington Regulations Law Specialist

Yuim I’roving Ground 6/19/90 Mark Smith Housing Engineer Technician

-- Timothy R. Novak Cultural Archeologist Resources

_- Charles Botdorf Hazardous Physical Scientist Waste, Geology

Paulette M. Saunders General Chief, Environment environ Division mental

Valerie Morrill Wildlife Wildlife Biologist Biology

5 - 10 6/21 /90 Chuck Wullenjohn Employ- Public Affairs ment

Stanley McGowen General Chief Warrant Officer Operations

U 5 Ilcpl. of the Susanna C. Henry Wildlife Intt.rior, Uureau of Wildlife Biologist Biology I~ndManagement, Yuma Yuma Resource Area IhLrict Office

Kol,i National Wildlife Mike Smith Wildlife, I

Impc~i.ilNational Will Nidecker Wildlife, Wildlifc I

USFWS, I’hoenix Field Gilbert Metz Officc, Office Manager

Leslie Fitzpatrick Mammals

Sue Rutman Plants

Robert Mesta Birds

Sally Stefferud Inverte- brates

5.3 COMMENTS ON DRAFT EIS

< IIIIIIII~IILSreccivd concerning the Draft ElS and responses to coiiirnents are incorporated in Aplirtidix M. Transcripts of the public meetings of the Draft EIS also are presented in Appendix M.

5.4 l~Ul~’11IEK I’UBLIC INVOLVEMENT

Adldilion,il opportunities for public involvement and agency coordination exist during the rcwi,iindcr 01 the EIS process. There is a 30day public review period after the Final EIS is published

5 - 11 and distributed. Public notices of these actions will be provided, as well as press releases and oflicial Notification of Availability in the Federal Register.

5 - 12 CHAPTER 6 - LIST OF PREPARERS

The persons responsible for the preparation of this Environmental Impact Statement include representatives from the U.S. Amy Corps of Engineers, Louisville District (JPG) and LQS Angeles District (YPG), WAPORA, Inc. (JPC),Michael Baker Jr., Inc. UPC) and Chambers Group, Inc. (WG).

Education and Primary Exwrience Responsibilities

6.1 JEFFERSON PROVING GROUND

United States Armv Corns of Eneineers. Louisville District

James M. Baker B.S. Zoology Project Coordinator 16 years experience in aquatic ecology and environmental impact assessment. Experienced in project design, management and report preparation.

WAPORA, Inc., Prime Consultant

Alyse Cetty B.A.Environmenta1 Science; Project Manager; overall 8 years of experience as an planning, coordination ecologist, involved in manage- and review. ment of various environmental, water resources, wetland mapping and permitting projects.

Scott Fletcher MEM Environmental Policy/ Asst. Project Manager, Economics; B.S. Wildlife data collection and Ecology; 4 years of preparation of Wildlife experience in multi- Biology section. disciplinary environmental assessments, including wetland analysis, terrestrial surveying and report preparation.

6-1 Carol Vassallo B.S. and MS. Geology; Data collection and 3 years of experience in preparation of Water geology, water resources, Resources and Soils and coastal geomorphology. sections.

Selma Hanel MS. Botany; B.A. Biology; Data collection and 5 years experience in field preparation of Vegetation surveys, literature reviews, section. impact assessments, plant identification and wetland delineations.

Fred Hamburg Ph.D. Cadidate Mechanics; Data collection and M.S. Meteorology and Ocean- preparation of Air ography; B.A. Mathematics; Quality, Climate and 30 years experience in Noise sections. environmental pollution abatement with emphasis in air quality and meteorology.

Les FIynn M.B.A. Fince; M.S. Forest Data collection and Resources; B.S. Biology; preparation of Aquatic experienced in project Ecology and Wetland design, statistical analysis, sections. management and report preparation.

Dave Sond M.B.A. Economics; M.S. Soil Data collection and Chemistry; 19 years of experience preparation of the in natural resources, soil Hazardous Materials sciences energy and resource section. recovery, solid and hazardous waste, environmental assessments and policy analysis.

6-2 leanninc Kreinbrink B.A. Anthropology; Data collection and archeologist experienced in preparation of directlng Held and laboratory Cultural Resources projects, including analysis section. and curation of artifacts.

Michael Baker, Ir.,Inc. (Subconsultant responsible for socioeconomic and reuse analysis)

James R. Daley B.S. Environmental Resource Quality Control/ Management; 10 years experience Assurance and in field surveys, environmental technical input for impact statements, environmental Chapters 1,2,3,and 4. assessments, and environmental permitting requirements.

Louis J. Maslyk, Jr. M.S.Urban and Regional Planner-in-Charge; Planning; 9 years experience data collection and in providing technical input preparation of Chapters 1, and planner-inqharge experience 2, 3, and 4. for comprehensive planning projects, environmental assessments/ impact statements, land use and socioeconomic planning components project planning and development, and site development projects.

William 1:. Clement M.A. Geography and Regional Data Interpretation and Planning, B.A. Geography; incorporation of I.W.R. experienced in military master BRACO SEA analysis planning and report preparation. into sections of Chapters 3 and 4.

6-3 6.2 YUMA PROVING GROUND

United States Armv Corns of Eneineers, Los Aneeles District

Ron Ganzfried M.L.A. Landscape Project Manager; overall Architecture; B.A. Geography planning, coodination and and Environmental Studies; 12 review years experience in management of complex projects involving water resources, coastal resources, environmental planning, design and assessment, and report preparation.

Jonathan Freedman M.S. Geography; 8 years Associate Project experience in environmental Manager; data collection planning, management, assessment and assessment; coordination and NEPA compliance; dryland ecology and remote sensing

Ronald Conner B.A. Economics; 6 years Economic analysis and experience in economic review of socioeconomic analysis. effects

Steven Dibble M.A. and B.A. Archeology; Data collection and 8 years experience in collection of Cultural southwestern archeology Resources sections and Federal cultural resources planning, and assessment compliance

Michael Noah M.S. Biology; 9 years Supervising experience in terrestrial Reviewer marine ecology, biostatistical analysis, and NEPA compliance

6-4 CI IAMBERS GROUP, INC.

John W cstermeier M.A. Biology; 15 years Project Manager of experience in project Socioeconomics management for environmental and biological assessments.

Ph.D. Biology; 10 years Vegetation experience in assessing botanical resources in both coastal and desert plant communities.

Todd lhdy B.A. Environmental Biology; Noise, Hazardous 12 years experience in Materials, Air implementing waste Quality assessment and environmental analysis programs and noise and traffic analyses.

B.S. Biology; 10 years Socioeconomics, experience in environmental scoping, chemical analysis, transportation biological assessments, and monitoring, and EIS preparation.

DiA nnc’ Vnlcntine B.U.S. Environmental Land Use and Planning; 10 years Cartography experience in land use analyses, cartography, community /regional planning, and other socioeconomic studies

U.A. Anthropology; 5 years Cultural Resources experience in data collection, fieldwork, and curation.

6-5 M.S. Wildlife Science; Wildlife 3 years cxpericnce in perfomling biological assessments and surveys.

Waviic Oakes B.A. Archeology/ Paleontology Paleontology; 12 years experience in archeological and paleontological monitoring, survey, excavation, and laboratory services.

Mnri Schrocvicr B.S. Zoology; 5 years Wildlife experience in wildlife assessment .

Jellcry Knulmann M.S.Zoology; 6 years Wildlife experience in wildlife assessment.

Philip de Barros Ph.D. Archeology; 12 years Cultural Resources experience in Cultural Resource Management.

Kcw I .ord Ph.D. Anthropology; 15 years Cultural Resources experience in Cultural Resource Management.

6-6 CHAPTER 7 - DISTRIBUTION AND REVIEW OF DEIS

7.1 NATIONAL

Administrator Division of NEPA Affairs Agricultural Research Service Department of Energy Ikpartmcnt of Agriculture 100 Independence Ave., Rm 4G064 Washington, DC 20250 Washington, DC 20210

Assistant Secretary Director Director, Environmental Project Office of Environmental Affairs Review Office, USDl Dept of Health and Human Services 18th and C Streets, Room 424-1 330 Independence Ave., SW Washington, DC 20240 Washington, DC 20201

Assistant .Secretary Director for Occupational Safety & Health Office of Environmental Quality I)cpnrtmcnk of Labor Dept. of Health and Human Services 200 Constitution Ave., NW 451 Seventh Street, SW Washington, DC 20210 Washington, DC 20401

Dcputy Assistant Director Scrrctary Iimd & Water Office of NEPA Affairs I>cpartment of Interior U.S. Department of Energy Washington, DC 20240 Washington, DC 20545

Ilircctor Director 1luri.a~of Land Management US. Fish & Wildlife Service Ikpartment of Interior Department of the Interior Wnshini;ton, DC 20240 Washington, DC 20240

I>ircrlor Mr. Bruce Blanchard, Director Offi(w of linvironmental Quality Environmental Project Review Offic-c of thv Assistant SEcretary U.S. Dept. of the Interior for Knv., S.ilcty & Consumer Affairs 18th and C Street, Rm. 424-1 Wa~liinglon,IX 20590 Washington, DC 20240

7-1 I i 11 vi rimmcmta I Defense Fund National Audubon Society IS25 18th Street, NW 1511 K Street, NW Washington, DC 20036 Washington, DC 20005

Mr Kenneth W. Holt Secretary I>cpt. of Ilealth & Human Services Dept. of Veterans Affairs ('enter for Env. Health Spec. Prog. Central Office Center for Disease Control 810 Vermont Ave., NW Atlanta. GA 30333 Washington, DC 20420

National Wildlife Federation Office of the Deputy Assistant I Iirector of Federal Affairs Secretary for Environmental Affairs 1412 16th St., NW U.S. Department of Commerce Washington, DC 20036 Washington, DC 20230

Mr. Wally Bishop, Sr. Office of Architectural & I'rojcct Manager Chief, Eastern Division of Project Review Office of Economic Adjustment Advisory Council on Historic Ikpirtment of Defense Preservation 'l'hc I'entagon, Rm 4C 767 Old Post Office Building Washington, DC 20301 1100 Pennsylvania Ave, NW, Suite 809 Washington, DC 20004 William Franz, Chief Environmental Rev. IiI'A I'lanning and Mgt. Division, Reg. 5 Sierra Club 230 S. Dearborn Street 324 C St., S.E. ('t1icq;o, 11. 60604 Washington, DC 20004

Mr john Scyffert I;(dcral iimcrgency Mgmt. Admn. 50(1 (' Strrc.l, llm. 713 Wti\hinj;ton, Ix' 20201

7-2 7.2 J I’G

Elected

I Ionorable Lee H. Hamilton Honorable Elwin M. Wooden 1 louse of Representatives Mayor of Madison 107 Federal Ctr. 416 West Street 1201 E. 10th Street Madmn,W 47250 Jcffersonville, IN 47132 Mr. Harold Yancey I lonomblc Dan Coats Jefferson County Conimissioner Unitd States Senate Madison, IN 47250 1:cdcml Ctr. 1201 li. 10th St. Mr. Harold Marsh Jeffersonville,IN 47132 Jennings County Commissioner Vernon, IN 47282 I lonorable Richard G. Lugar United States Senate Mr. Kenneth W. Copeland I:cderal Ctr. Ripley County Commissioner 1201 1;. 10th St. Versailles, IN 47042 Jcffcrsonville,IN 47132

I nd kina Wildlife Federation Ms. Susan J. Kennel1 I’.O Ilox 283 State Budget Agency %ionsville, IN 46077 212 State House Indianapolis. IN 46204 hlr. I.Eddleman Ms. Nancy A. Maloley Sk1~’ <:oiiservationisl IN Dept. of Environmcntal Mgmt. Soil (’orwwation Svc., USDA 105 S. Meridian Street 5610 Crawlordsville Rd., Ste. 220 P.O. Box 6015 Iiidiiinapolis, 1N 46224 Indianapolis. IN 46205

7-3 Mr Douglas M. Mason Mr. James M. Ridenour, Director I loosier Environmental Council IN. Dept. of Na turd Resources I'.O Ilox 1145 608 State Office Building Indi.inapolis, IN 46204 Indianapolis, IN 46204

Indiana Div. Engineer Mr. Patric Ralston, Director hderal Highway Administration State Historic Preservation Office U.S. Department of Transportation Dept. of Natural Resources 575 N. Pennsylvania St., Rm 254 608 State Office Building Indianapolis, IN 46204 Indianapolis, IN 46204

Mr. Bart Patterson Oflicc of [he Governor State of Indiana Statehouse, Room 206 Indianapolis, 1N 46204

Kegional

1:xecutive Director Regional Administrator lndtan'i 15 Regional Planning Comm Environmental Protection Agency 5 I1 1;ourtIi Street, P.O. Box 70 230 S. Dearborn Street I luntington, IN 47542 Chicago, IL 60604

Mr. I>on II.Castleberry Supervisor l

I(c~pona1Administrator, Region 5 US.Dept of Health, Ed &Welfare I)cp'L of I lousing & Urban Dev. Regional Environmental Office 700 5 W,icker 433 W. Van Buren St., Rm. 712 ('Iiii-~y,~,II. 60606 Chicago, IL 60607

7-4 1ky;ioii~iI lhgiiicer US. Dept. of Transportation 1:cclcral lincrgy Regulatory Comm Region V Secretarial Representative I:ederal Rldg. Room 3120 17th Floor, 300 W. Wacker Dr. Chicago, II, 60604 Chicago, IL 60606

Mr. Robert L. Mustard Mr. William D. Franz Iixleral Activities Coordinator Chief, Env. Review Branch Environmental Protection Agency USEPA 5ME-16 230 S. Dearborn Street 230 S. Dearborn Street Chicago, IL 60604 Chicago, IL 60604 linv. Review Officer Ikpt. of I lealth & Human Resources 300 S. Wacker Drive Chicago, II, 60606

]IT; Survival Committee Jefferson County Library P.0. Box 35 Madison, IN 47250 Madison, IN 47250 Jennings County Library Robert M. Eads, Pres. Vernon, IN 47282 Madison Industrial Dev. Corp 301 East Main Street Ripley County Library Madison. IN 47250 Versailles, IN 47042

7.3 YI’G

Iilected

I Ioiiorablc I)ob Denny Honorable Dennis Dwoncini Arizona State Senate 700 E. Jefferson Street Stmite Illdg., Capitol Complex Suite 200 I’hoenix, AX 85007 Phoenix, AZ 85202

7-5 I ionorable Fife Symington Honorable Herb Guenther Governor, State of Arizona P.O. Box 365 1700 W. Washington Tacna, AZ 85352 I’hoenix, AZ 85007

Ilonorable John McCain Honorable Jim Buster I51 N. Centennial Way, Suite IO00 2240 Elks Lane Mesa, AZ 85202 Yuma, AZ 85364

Ilonorable Morris Udal1 Honorable Robert McClendon 522 W. Koosevelt, Suite IO00 P.O. Box 1112 I’hocnix, AZ 85033 Yuma, AZ 85364

Ilonorable Robert Stump Honorable Jess Vela 230 N. 1st Avenue, Room 5001 Mayor of Somerton I’hoenix, AZ 85025 110 North State Street Somerton, A2 85350

Ilonorable Cleta Lopez Office of the Mayor Mayor of Wellton City of Yuma 2x634 Oakland Avenue 200 W. 1st Avenue Wclllon, AZ 85356 Yuma, AZ 85364

Arizona Ikpt. of Env. Quality Mr. Gerald Eletzke, Director (’ livans-Carmichael, Remedial Arizona Dept. of Env. Quality 15 South 15th Avenue 2005 N. Central Ave. I’hocnix, A2 85007 Phoenix, AZ 85004

Ijill Werner, Reg. Habitat Sp. Arizona Game and Fish Dept. Arizona Game and Fish Dept. Larry Voyles 0005 S. Pacific 3005 S. Pacific Avenue YIIIIXI,A% 85365 Yuma, A2 85365

Arimiici (;anie and Fish Dept. State Historic Preservation Officer 2222 (;reenway Road 800 W. Washington, Suite 415 I’liocwix, A% 85023 Phoenix, AZ 85007 .

7-6 Arizona Ihpt. of Transportation Arizona State Clearinghouse Urban Highway Section, Room 118 Dept. of Comm., 4th Floor, Ex. Tow 205 S. 17th Avenue 1700 W. Washington I’lioenix, A2 85007 Phoenix, AZ 85007

Robert Gasser, Archeologist Arizona State Parks Dept. Arimna State Parks 800 W. Washington, Suite 415 800 W. Washington, Suite 415 Phoenix. A2 85007 Phoenix, AZ 85007

Arizona Flores, Red. Coord. Arizona State University Arizona State Parks Site Stwd. Center for Env. Studies 2530 Ihrbara Avenue Tempe,AZ 85287 Yuma, AZ 85365

Mr. Don Denton Arizona Dept. of Water Resources Slate Uoard of Transportation 99 E. Virginia Avenue Izoute 2, Box 736 Phoenix, A2 85004 I’arkcr, A2 85344 llepional

Arizona Riparian Council Bureau of Reclamation (‘enter for Env. Studies Lower Colorado Regional Office Ari~onaSlate University P.O. Box 427 ‘I twlpc, A% 85287 Boulder City, NV 89005

I.~riiicrsI lome Administration Ms. Claudia Nissley 201 1.1. Indianola, Suite 275 Chief, Western Division of I’l~~it~nix,A2 85012 Project Review Advisory Council on Historic I ower Colorado River Resources Preservation l’Eirkc,rl’own Hall 730 Simms Street, Suite 450 1314 11th Street Golden, CO 80401 I’AI~LT, A% 85344

7-7 Maricopa Audubon Society Arizona Desert Bighorn Sheep 4619 E. Arcadia Lane Dean Bowdoin Phoenix, A2 85018 l’.O. Box 5241 I’hoenix, AZ 85010 Arizona Nature Conservancy Mr. Peter Warren, Public Lands 300 E. University Blvd. Tucson, A2 85705 Arizona Native Plant Society IW. Box 41206 ‘I’iicson,AZ 85717

Sierra Club, Grand Canyon Chapter Wilderness Society Ms. Joni Bosh, Chair Jim Norton 21 21 7 East Osborn 234 N. Central Avenue, Suite 430 I’hoenix. AZ 85016 Phoenix, A2 85004

Arizona Wildlife Federation The Wilderness Society 4330 N. 62nd Street Arizona Chapter Suite 102 P.O. Box 11135 5ottsdale. AZ 85251 Phoenix, A2 85017

I i I I viron men ta I Protection Agency John C. Wise, Regional Administrator I:cderal Activities Branch (P5) Environmental Protection Agency 21 S I;reinuiit Street 215 Fremont Street S.111 I:rancisco, CA 94105 San Francisco, CA 94105

Ari~(in.iDaily Star Tucson Citizen St~rI’ublishing Company Citizen Publishing Company I’ 0 Ihx 26807 P.O. Box 26767 I w‘son, A% 85726 Tucson, AZ 85726

CJSIII 1;ish and Wildlife Service Joseph Maygum, Acting Reg. Dir. I koIoj;icci I Services USDI Fish and Wildlife Service %IO W. ‘I’homas, Suite 6 P.O. Box 1306 l’liocwix, A% 85019 Albuquerque, NM 87103

7-8 11SI)l I:ish and Wildlife Service USDl Fish and Wildlife Service 50ll (hid Avenue Southeast Havasu National Wildlife Refuge l’.O. Ihx 1306 P.O. Box 3009 Alhuqwrque, NM 87103 Needles, A2 82363

13LM BLM 2475 Beverly Avenue Yuma District Office Kingnian, A2 86401 P.O.Box 5680 Yuma, AZ 85365 Mr. Herman Kast 131.M 3150 Wirisor Avenue Yuma, AZ 85364

Mr. Danny Bryant Mr. Pat Connor Ilodrd of Supervisors Board of Supervisors 168 2nd Avenue 168 2nd Avenue Yunin, AZ 85364 Yuma, AZ 85364

Mr. Bobby McClendon Mr. Pete Woodward Iloard of Supervisors Board of Supervisors I68 2nd Avenue 168 2nd Avenue Yunia. A% 85364 Yuma, AZ 85364

Mopvc County County of La Paz Ihird of Supervisors P.O. Box C 1’0. l3ox 390 Parker, A2 85344 Kiiipii‘in, A% 86401

Slwrill John I’liipps Mike Daily 14.5 S. 3rd Avenue 8101 S. Highway 95 Yuiiia, AZ 85364 Yuma, A2 85364

7-9 Mr. Kcnnelh Evans Tedd Tarwater 1526 S. 5th Avenue DYN Corp Yuma, AZ 85364 835 E. Cactus Drive Yuma, AZ 85364

Michael Fox Robert Green Southwcst Bowhunter 1340 6th Avenue 738 E. I’lace Yuma, AZ 85364 Yunia, AZ 85364

<;.I,. Gould, Manager Don Kieland, President Welllon-Mohawk IRR/DR District Don Kieland Mat. Inc. Iloute 1, Box 19 3140 Windsor Avenue, Apt. 17 Wellton, AZ 85356 Yuma, AZ 85364

City of Scottsdale Jim Morton City Manager 234 N. Central Avenue 3939 Civic Center Plaza Suite 430 Scottsdale, AZ 85251 Phoenix, AZ 85004

Yuinci Women’s Reel & Rifle Club Yuma Rod & Gun Club I’.O. Ikix 1621 John Fugate Yuma. AZ 85365 2438 13th Place Yuma, AZ 85364

Keiin and Kati Scott Yuma Valley llod and Gun Club l’.O. Ik~x4326 P.O. Box 1806 Yuma, AZ 85365 Yuma. AZ 85364

Hill Kerekcs Lany Knight, President Yu~n~iValley kid and Gun Club Yuma Valley Rod and Gun Club 1210 17th I’lacc 16110 E. 3rd Street Yuma, A% 85364 Yuma, AZ 85364

Boma Johnson Yuma Archaeological Society 798 W. 25th Street Yuma, AZ 85364

7 - 10 Yuin.~Auduhon Socic4y Sierra Club ‘.I ry Mcister Jerry Nelson IY). Ikix 6395 711 E. LcLellan Yunia, A% 85364 Yuma, AZ 85364

Ihss America Betty’s Kitchen Protective Ax. c/o Joe Tex, lnc. Ms. Pat Callahan. I1.O.I%ow 35816 3150 Winsor Avenue Phoenix, AZ 85069 Yuma, AZ 86265

Sierra Club Arizona Native Plant Society Yuma Chapter Betty Davenport Anna Sandoval, Spokesperson 4138 S. 14th Street Yunia, A2 85365 Yuma, AZ 85364

Jim Ureck, Director Bill Van Ouden Arizona Wildlife Federation P.O. Box 4792 2473 Kathleen Avenue Yuma, AZ 85364 Yuma. A% 85364

Yuma Daily Sun Samuel Petter, Publisher Tiin Schultz, Staff Writer Yuma Daily Sun 2055 Arizona Avenue 2055 Arizona Avenue Yuma, AZ 85364 Yuma, AZ 85364

I .cc I’oole, General Manager Pete Weisner, Bureau Chief KI31.U KECY-TV 1120 S. 4th Avenue 242 W. 28th Street YLIIIXI,AZ 85364 Yuma, AZ 85364

Kiin Johnson, News Director James Stowe, General Manager K IX:\KJOK Radio KIX 20Y5 Olivia Avenue 699 S. Avenue D Yuma, AZ 85364 Yuma, A2 85364

7-11 Ikrb Hardy, General Manager Peter Posella, General Manager KAWC KYEL-TV Arizona Western College 1301 S. 3rd Avenue Yuma. A2 85365 Yuma, AZ 85364 lid I ockwood, Ccncrill Managcr Keith Martin, General Manager KYMA-TV KYXI 1385 S. Pacific Avenue 255 4. 24th Street Yunia, A% 85364 Yuma, A2 85364

Mr. Tom McCraley, Supt. Andrew Jack Dail, Supt. School District 1 Mohawk Valley School District 450 W. 6th Street P.O. Box 67 Yuma, AZ 85364 Roll, A2 85347

Mr. Ray Drysdale, Supt. Lt. Dan Mitchell, District 4 Yuma School Department Dept. of Public Safety I68 2nd Avenue 2111 E. Gila Ridge Road Yunia, AZ 85364 Yuma, A2 85365

J .I).White R.F. Woodhouse 900 I. I’alo Verde WMIDD Board Yumn, AZ 85364 Route 1, Box 74 Roll, AZ 85347

(‘01. W. Miller, Commander Chuck Bodfort LJSA Yuma Proving Ground USA Yuma Proving Ground l’.O. I3ox 3128 1408 Cypress Point Yuma, A2 86365 Yuma. AZ 85365

Art Stoddard, Project Eng. Carole Coleman lJSACII P.O. Box 3353 LISA Yuina Proving Ground USA Yuma Proving Ground Yunhi, AX 85365 Yuma, AZ 85365

7-12 IJruce hbbs Ron Gage, Logistics Director Planning Office USA Yuma Proving Ground USA Yuma Proving Ground 1734 W. 26th Street Yuma, A2 85364 Yuma. AZ 85364

Chry Gray, Director Res. Mgt. Loren Martindale, Pers. Off. USA Yuma Proving Ground USA Yuma Proving Ground 101 67 Del Rio 1746 W. 25th Land Yuma. AZ 85365 Yuma, A2 85364 lay MQueen, Command JAG Valerie Morrill USA Yuma Proving Ground USA Yuma Proving Ground P.0. Box 3322 P.O. Box 3597 Yuma, A2 85365 Yuma, A2 85365

'I'iin Nowak, Archeologist Paulette Saunders, Chief USA Yuma Proving Ground Environmental Div. 12585 Del Rico USA Yuma Proving Ground Yuma, AZ 85365 AITN STEYP-ES-E Yuma, AZ 85365

Stcve Saunders, Chief Major R. Vanderlike, Director Solcty Division, USAYPG USAYPG Engineering and Housing 16116 li. Ch. 3th Street P.O. Box 3098 YLIIII~I,A% 85365 Yuma, AZ 85365

IAIIC~ Vander Zyl, Director William Vomocil, Tech. Dir. linv. and Safety, USAYPG USA Yuma Proving Ground 2512 W. 22nd Street 1143 Brahma Lane Yuma, A% 85365 Yuma, AZ 85364

Ihiri livms, Chairman Mr. Douglas Lowe Ytini.~Co. Chamber of Commerce City Manager 190 W. 14th Streel 180 W. 1st Street Y~IIILI,A?, 85364 Yuma, AZ 85364

7 - 13 Mr. [)avid Codley Mr. James Jefferson Yunia City Council Yuma City Council 180 W. 1st Street 180 W. 1st Street Yuma. AZ 85364 Yuma. AZ 85364

Ilriaii Rabiars, Ex. Dir. Mr. Donald Peterson C’ouncil of Governments Yuma City Council 1100 S. Maple Avenue 180 W. 1st Street Yunia. AZ 85364 Yuma, AZ 85364

Mr. John I

Mr. William Steiert Mr. Andrew Torres Yunia City Council County Administrator 180 W. 1st Street 168 2nd Avenue Yuina, AZ 85364 Yuma, A2 85364

Yunm County Public Works Dept. Dave Campbell, Director Mr. IhiFortney Yuma Development Services 2703 S. Avenue B 10184 Del Rey Yum;~,A% 85364 Yunia, AZ 85364

Mr. Ihn Soldwedel, Chair Mr. Dan Dorn Yurnd konomic Dev. Council Assistant City Manager 2155 S. 14th Avenue 180 W. 1st Street Yuma, AZ 85364 Yuma, AZ 85364

Ms. C:.irmcn Juziuk, Director Mr. Hector Acostn, Director C’cntcr for Employment Tr. Yuma Jobs for Progress 001 S. Main Street P.O. Box 352 Yumn, AZ 85364 Yuma, AZ 85364

7- 14 I

Mr. Bobby Robinson, Chie Mr. Ray Calderon City of Yunla Police Dept. Postmaster, US Postal Service 1500 1st Avenue Yuma, A2 85364 Yuma, AZ 85364

Yunia County Library Arizona Western College 350 So. Third Avenue AWC Library Yuma, AZ 85364 Yuma,AZ 85365

7 - 15 CHAPTER &INDEX

Acronyms ...... xi Affected Environnient ...... 2-2, 3-1 through 3-150 Agency Contacts ...... 5-4 Airport ...... 2-16,3-27,3-36,3-65,3-77, 3-78 Air Quality ...... 3-33, 3-34, 3-35, 3-104, 3-106, 3-108,443, 4-16, 4-26, 4-27 ...... 5-2, 5-5 Alternatives Considered But Eliminated ...... 2-25 Alternatives Considered Potentially Viable ...... 2-15 Ambient Air Quality ...... 3-33,3-34, 3-106 Aminunition ...... 1-2, 2-1, 2-2, 2-6, 2-7, 2-16, 2-18, 2-19,2-22, 3-24, 3-47, ...... 3-63,3-68,3-69,3-72, 3-124, 3-126, 3-127 3-136,3-140. 3-150 ...... 4-11,416.4-37, 4-39 Ani p 11 i bid 11s ...... 3-19,3-22, 3-24. 3-93 ASIWS~OS...... 2-11, 3-69, 3-70, 3-72, 3-73, 3-76, 3-77.3-147, 4-8, 4-20, 4-42 Ilasc Closure And Realignment Act ...... 1-1, 2-12 Iliological I&.ources ...... 3-89, 3-97 Uirds ...... 3-19,3-22, 3-24,3-93,3-94,4-6,4-29,s-4, 5-11 Climate ...... 3-1, 3-79, 3-143, 4-2, 4-21, 4-40 Construction ...... 2-1, 2-6, 2-7, 2-10, 2-17, 2-18, 2-19, 2-22, 2-25, 2-26. 3-16, ...... 3-38, 3-45, 3-47, 3-73, 3-76, 3-87. 3-111, 3-117, 3118,3426. 4-3, ...... 4-10, 412, 4-14, 4-21, 4-22, 4-23, 4-25,4-26, 4-27, 4-28, 4-29, 4-30, ...... 4-31, 432,4-33,4-36,4-37,4-39,440,443, 4-44 Cullur,~l Kcsources ...... 2-16, 2-17, 2-25, 3-34, 3-42, 3-44, 3-112,3-116. 3-118, ' ...... 4-9,4-31,4-32,4-44,4-45,5-3, 5-6 . Ikplcled Uranium (DU) ...... 2-11, 2-12, 2-19, 3-13, 3-16, 3-17, 3-70, 3-72, 3-75, ...... 3-136, 3-146, 3-150, 4-3, 4-19, 4-22.4-23, 4-24, 4-27, ...... 4-38,4-42,4-43.4-44,4-45 I~istriI~i~ti~~~~and review of DEE ...... 7-1 li. 1st Ann ...... 2-6, 2-22, 2.25. 3-82, 3-97, 3-101, 3-102. 3-103, 3-116.3-117. 3-118 ...... 3-120, 3-122, 3-127, 3-141, 4-1, 4-21, 4-22, 4-23, 4-24, 4.25, 4.29, ...... 4-30, 4-32, 4-33, 4-36, 4-37, 4.38, 4-40. 4-41, 4-43. 4-44 I~:c.~~oIII~...... 3-1, 360, 3-115, 4-13, 4-14, 4-33, 4-44 1:ducation ...... 3-126, 3-132 (see also Scl~ools) Ihhdnrcrl I'reliminary Assessment ...... 2-11, 3-69. 3-70 linvironniental Consequences ...... 1-2 hrosion ...... 3-8, 3-12, 3-18, 3-83, 4-1, 4-2, 4-3, 4-4,4-5, 4-7, 4-22, 4-23, 4-27 1;iriiij; I<;irigcs ...... 3-110, 4-42 1~'loodpl;iins...... 3-46, 3-50 (;cology And Mineral Resources ...... 3-2, 3-79. 4-2. 4-21 (;rorii~dwalcr...... 2-11, 3-12, 3-13, 3-73, 3-77, 3-83,3-87,4-3, 4-4, 4-23, ...... 4-41, 5-6 1Iaz.irdous Materials ...... 2-11, 3-41, 3-66, 3-69, 3-72, 3-136, 3-146, 3-147, ...... 3-150,4-1,4-19,4-38,4-42, 4-44 1 Ierbicidcs ...... 3-17, 3-18, 3-28,3-29, 4-5, 5-1 I listoric htc5>...... 344, 3-46,3-47,3-119, 4-31 I lousing ...... 2-25, 3-12, 3-38, 3-41, 3-52, 3-58. 3-60,3-62, 3-67, 3-69, 3-110, ...... 3-116, 3-126, 3-130, 3-145, 4-10, 4-12, 4-14, 4-18, 4-27, 4-33,

I 1511'...... 4-36,4-37,5-4,5-6,5-7, 5.10 w iAl

...... 3-12 .. I Iriiiian hvironment ...... 3.1. 3.41. 3.111.4.9.4.30. 4-43 Inipleinentation Alternatives ...... 2.18. 2.25. 4.1. 4.21. 4.23. 4.24. 4-25. 4.26...... 4;27.4.30. 5.2 Industrial Operations ...... 3.70. 3-72 Installation Restoration Program (IRP) ...... 2.1. 2-17 lrrcversiblc And Irretrievable Commitment Of Resources ...... 4-44 Instilule for Water Icesources ...... 3.51, 3.52, 3.54. 3.59, 3-60. 4-9. 4-10 . 4.11, ...... 4-12.4-13.4.14. 4-29 IWK ...... 3. 52, 3;5~,&60,.3-61,.4-10,4-11,4-12. 4.13, 4.14. 4-15. 4-33 JPC Development Board ...... 2.12.2.13.2.16,2.17. 4-13 Kofa Range ...... 2.18. 2.19, 3.92,3.102. 3.103. 3.118.3.119. 3-120. 3.127.3.141...... 3-.IA3,3-150,4-1,4.23. 4.24. 4.25.4.26.4.27,4-30,438,442,443. 4-45 hkes ...... 3.17.3.28,3.32,3.67.3.87. 3.93 landlills ...... 3.13. 3.70, 3.73. 3.147,4-3.4.17. 4-18 Land Use ...... 2.14, 2.16. 2.17.3.24. 3-41. 3-48. 3-50.3.53, 3.58. 3.62.3.66...... 3-75, 3.110, 3.124, 3.127. 4.10, 4.11, 4.12, 4-37, 4-45, 5-3 Lead Iaint>‘ ...... 3-77 List.OfFigures ...... ix List Of Preparers ...... 6-1 ListOfTabIes ...... vii Mammals ...... 3.19. 3.24, 3.94. 3.95. 3.101. 3.102. 3-103, 4.25. 5-11 Mcdical Services ...... 3-61.3.62. 4.37 Mercury ...... 3.82. 3.115 Mission ...... 1.1. 1.2. 2.1. 2.2. 2.6. 2.7. 2.9. 2.11. 2.19, 2.26. 3.18. 3.22...... 3-32. 3.37. 3-50. 3.52, 3.58. 3.61. 3-62.3-68. 3.120. 3.141...... 3.145, 3.150. 4-5. 4.9. 4.11. 4.12. 4-14. 4.16. 4.17. 4.18. 4.21...... 4.24. 4.26. 4.27. 4.37, 4.39. 4.41. 5-3 Munitims ...... 1.1, 1.2, 2.2, 2.6, 2.15, 2.16, 2.18. 2.19, 2.22, 2.25. 2.26. 3.18...... 3.29. 3.72.3.73,3.75. 3.76, 3.78.3.116.3.120,3.127.3.136,3.141. 3.150, ...... 4.7. 4.16. 4.21, 4.22. 4.23. 4.24. 4.25. 4.27, 4-30. 4.37. 4-39...... 4.42.4-43.4-44.4.45. 5.2 Native Aiiierican Values ...... 3-42, 3.112, 4.9. 4.30 Naluriil Areas ...... 5-6 Noise...... 3.1, 3.36. 3.37, 3.38. 3.41. 3.50. 3.110. 3.111. 4-6. 4.9. 4-15...... 4-24, 4.25, 4.27. 4.28. 4.29. 4.30. 4-43. 44. 5.2. 5.6. 5-7 No Action Alternative ...... 2-1 Odor ...... 4-27 I’A ...... 4-32 I’alc*wilology ...... 3.8. 3.83.4.2. 4-23. 5-6 I ,.C I%> ...... 2.11.3.76.3.147. 4.19 i’cmnit ...... 3.16. 3.17. 3.36. 3.65. 3.70. 3.72. 3.75.3.77. 3.78, 3.136. 4.8. 4-44 I’c*slic.idc.s ...... 3.17. 3.18, 3.29. 3.136, 4.2, 4.5. 4-27 .. I’liysi~~nlI:iivironnient...... 3-1 l’opiildticii~...... 2.2, 2.10. 2.17. 3.19. 3.22. 3.48. 3.52. 3.53. 3.58. 3.104. 3.112...... 3.113, 3.122, 3.124. 3.127, 3.130. 4.5. 4.10, 4.11, 4-12. 4.13. 4.25, ...... 4.29. 4.33, 4.36. 4.37, 4-39. 440. 4-43 l’reliistoric Resources ...... 3-46. 3-119 I’ropcrty 1)isposition...... 2-12 Purpse atid Need for the Action ...... 1-1 I

9.1 JI

1%. and I’.W. Business and Professional Women. 1967. History of Ripley County, Indiana. Osgood, Versailles, Milan, and Holton, Indiana.

Ilendcll, J.F. 1974. Effects or fire on birds and mammals. In T.T. Kozlowski and C.E. Ahlgren (eds.), Fire and Ecosystems. Academic Pres, Inc., New York.

Muyd, Richard M., Jr. 1974. Summary of appraisals of the nation‘s groundwater resources - Ohio region. U.S. Geological Survey Professional Paper 813-A: Groundwater development and management opportunities in the region. U.S. Government Printing Office, Washington, DC.

Ilrack, V.M. 1983. The nonhibernating ecology of bats in Indiana with emphasis on the endangered Indiana bat, Mvotis sodalis. Phd Thesis, F’urdue University, Indiana.

Ilriick, V., A.M. Wilkerson, R.E. Mumford. 1984. Hibernacula of the endangered Indiana bat in Indiana. l’roceedings of the Indiana Academy of Sciences. Vol. 93, pp. 463-468.

Iluilding Technology, Inc. 1984. Historic properties report for the Jefferson Proving Ground. For the I IAUS/HA Engineering Record, National Park Service, US. Department of the Interior.

Ilurt, W.1 I., and R.P. Grossenheider. 1976. A field guide to the mammals. Houghton Mifflin Company, Hoslon, Massachusetts.

Conant, I<. 1975. A field guide to reptiles and amphibians of eastern and central North America. I loughton Mifflin Company, Boston, Massachusetts.

Coolx’r, James L. 1989. Letter from James L. Cooper, Professor of History, DePaul University, Greencastle, Indiana, to John L. Carr, Senior Environmental Specialist, Division of Historic I’rcscrvation and Archeology, Indianapolis, Indiana; dated 18 March 1989.

(‘rc,L,, I ). 198Y. Archeological field reconnaissance of the Webb Borrow Pit, Ripley County, Indiana. 1h11 State University, Muncie, Indiana.

I)cr\b, John IY8Y. Personal communication, Mr. John Doss, Division of Air Management, Indiana I )cpirtmenl of Environmental Management, Indiana. October 1989. hrly, Mikc. June 1990. Personal communication, Mr. Mike Early, U.S. Army Test and Evaluation Conwund, JPG. l:eIJt, KII. 1Y87. Indiana state and wildlife research. Pittman-Robertson Project No. W-Z&R-l5.

9-1 Wildlife Resources ...... 2-25, 3-18, 3-19, 3-20, 3-22, 3-28, 3-67, 3-87, 3-92, ...... 3-95, 3-97, 3-101, 3-102, 3-10.5, 4-5, 4-25, 4-44 Zoning ...... 3-41, 3-48, 3-50, 3-110, 3-120, 4-9, 4-32, 5-4, 5-5 CHAI'TER 9 - REFERENCES

9.1 J1~I:I~L:RSONI'ROVING GROUND llakcr, Miclyael, jr., Inc. 1987. Letter from Louis 1. Maslyk, Jr., Planner, to Cindy Brubaker, Division of I listoric and Archeological Preservation, Indianapolis, Indiana; dated 3 December 1987.

13. and P.W. Business and Professional Women. 1967. History of Ripley County, Indiana. Osgood, Versailles, Milan, and Holton, Indiana.

Ilcndell, J.F. 1974. Effects or fire on birds and mammals. In T.T. Kozlowski and C.E.Ahlgren (eds.),Fire and Ecosystems. Academic Press, Inc., New York. liloyd, Richard M., Jr. 1974. Summary of appraisals of the nation's groundwater resources - Ohio region. U.S. Geological Survey Professional Paper 813-A: Groundwater development and management opportunities in the region. U.S. Government Printing Office, Washington, DC.

Iirack, V.M. 1983. The nonhibernating ecology of bats in Indiana with emphasis on the endangered Indiana bat, Mvotis sodalis. Phd Thesis, Purdue University, Indiana. llriick, V., A.M. Wilkerson, R.E. Mumford. 1984. Hibernacula of the endangered Indiana bat in Indiana. I'roccedings of the Indiana Academy of Sciences. Vol. 93, pp. 463-468.

Iluildiiig Technology, Inc. 1984. Historic properties report for the Jefferson Proving Ground. For the I lAUS/HA Engineering Record, National Park Service, US. Department of the Interior.

Ihrt, W.1 I., and R.P. Crossenheider. 1976. A field guide to the mammals. Houghton Mifflin Company, Boston, Massachusetts.

C0nant, I<. 1975. A field guide to reptiles and amphibians of eastern and central North America. I loughton Mifflin Company, Boston, Massachusetts.

CooI)cr, Jiinies L. 1989. Letter from James L. Cooper, Professor of History, DePaul University, (kencastle, Indiana, to John L. Cam, Senior Environmental Specialist, Division of Historic I'reservation and Archeology, Indianapolis, Indiana; dated 18 March 1989.

<'rc(,. I). 1989). Archeological field reconnaissance of the Webb Borrow Pit, Ripley County, Indiana. 1L111 Slate University, Muncie, Indiana.

IAish, JoIii1. 1989. Personal communication, Mr. John Doss, Division of Air Management, Indiana I kpirtnicnl of Environmental Management, Indiana. October 1989. liirly, Mike. June 1990. Personal communication, Mr. Mike Early, U.S. Army Test and Evaluation C'oinmmd, JPC.

14Jt. 11.1). 1987. Indiana state and wildlife research. Pittman-Robertson Project No. W-26-R-15

9-1 I;tryst, Joe. 1989. Personal communication, Mr. loe Foyst, Division of Air Management, Indiana Ilepartment of Environmental Management, Indiana. September 1989.

(;lcwic, I

Grcsliam and Company. 1889. Biographical and historical souvenir for the Counties of Clark, Crawford, Harrison, Floyd, Jefferson,Jennings, Scott, and Washington, Indiana. Chicago, Illinois.

(helidling, R.L. 1975. Archeological resources of the proposed surface, gunnery range, Jefferson I’roving Grounds. Prepared for Ralph H. Burke Associates, by Glenn A. Black, Laboratory of Archeology, Indiana University, Bloomington, Indiana. liarper, Anthony. 1990. Personal communication, Mr. Anthony Harper, DOD Office of Economic Adjustment.

Hill, John K. no date (n.d.). The geology of Indiana: a general summary. Unofficial publication of the Indiana Geological Survey. Bloomington, Indiana.

Historic Landmarks Foundation of Indiana. 1986. Ripley County Interim Report. Completed for the Indiana Historic Sites and Structures Inventory. Published by the Historic Landmarks 1:oundation of Indiana.

. 1988. Hoosier Landmarks. Indiana Properties Listed in the National Register of Historic . I’l.1CCS.

. 1989. Jennings County interim report. Completed for the Historic Sites and Structure Inventory. Published by the Historic Landmarks Foundation of Indiana, Indianapolis, Indiana.

Ilolzwortlr, George C. 1972. Mixing heights, wind speeds and potential for urban air pollution throughout the contiguous United States.

I ludnk, David C. 1991. Letter from David C. Hudak, Supervisor, U.S. Department of the Interior, Fish and Wildlife Service to Scott Fletcher, Wildlife Biologist, WAPORA, Inc. Bloomington Field Olfice, Bloomington, Indiana.

I luddk, Ikivid C. 1989. Letter from David C. Hudak, Supervisor, US.Department of the Interior, Fish and Wildlife Service to Selma Hanel, Botanist, WAPORA, Inc. Bloomington Field Office, ~~~(J(JliiiligtOn,Indiana.

Iiidilin.i I )cpartnwnt of Environmental Management (IDEM). 1989. Report to the Governor; US.Army Jc4ft.rson I’roving Ground Evaluation. Prepared by CH2M Hill for IDEM, Madison, Indiana.

IIiJi,in,i I>cp;irtincnl of Natural Resources. 1988. Eye on wildlife: rare species report. Indiana I)cpirtnienl of Natural Resources, Division of Fish and Wildlife. Indianapolis, Indiana.

9-2 India titi Siatc I listoric l’reservation Office (SHPO). July 1985. Letter from Laura Thayer, Architectural I lislorian, Division of Historic Preservation and Archeology, to Thomas L. Roller, Director, Logistics, Jefferson Proving Ground, Madison, Indiana.

__ . January 1986. Letter from James M. Ridenour, State Historic Preservation Officer, to ‘l’homasL. Roller, Director, Logistics, Jefferson Proving Ground, Madison, Indiana.

. December 1987. Letter from James M. Ridenour, State Historic Preservation Officer, to Louis J. Maslyk, Jr., Michael Baker, Jr., Inc.

-~- . 1989a. Letter from John L. Cam, Senior Environmental Specialist, to Dr. James L. Cooper, I’rolessor of History, DePaul University, Greencastle, Indiana; dated 10 February 1989.

__. 1989b. Letter from John L. Carr, Senior Environmental Specialist, to James A. Fritsche, P.E., Direclor of Engineering and Housing, Jefferson Proving Ground, Madison, Indiana; dated 10 February 1989.

~~~ . 1989c. Letter from Patrick R. Ralston, State Historic Preservation Officer, to James A. I:ri

Jcrmdn, C. Ed. 1888. History and Directory of Ripley County, Indiana.

Joshi, Kaushik. 1989 and 1990. Personal communications, Mr. Kaushik Joshi, Environmental Officer, 11’6.

Kariis, IXiryl, I<. 1986. The amphibians and reptiles of Jefferson County: Analysis of a herpetological community in southeastem Indiana. Submitted to the lndiana Nongame and Endangered Wildlifr Program, Bloomington, Indiana.

1Y8Y. Personal communication, Dr. Daryl C. Karns, Assistant Biology Professor, 1hwvc.r < ‘01 I(.gc, India na.

Kcllcr, Cli.,S.A. Kcller, and T.C. Keller. 1986. Indiana birds and their haunts. Midland Books, U.S.

Knoul, KI~.lY89 and 1990. Personal communications, K. Knouf, JPG Natural Resource Manager, IPG.

I sifL-rriims, A.II., I1.E. Hattin, C.J. Foell, and T.F. Abdulkareem. 1986. The Ordovician-Silurian uiwitiformity in southeastern Indiana. Indiana Department of Natural Resources, Geological Survey. Occasional Paper 53. Bloomington, Indiana.

Iiiucr, ‘1’. 19YU. Personal communication, Tom Lauer, Indiana Department of Natural Resources, May 1990.

l,ouis, I)r. J. 1989. Personal communication, Dr. Louis, U.S. Army Environmental Hygiene Agency. ALierJeen Proving Ground, Maryland, September 26,1989.

9-3 I.iiz, Or. Chrge. 1989. Personal communication, Dr. George Luz, U.S. Amy Environmental Hygiene Agency, Aberdeen Proving Ground, Maryland, September 18, 1989.

Mcdlend, J. 1990. Personal communication, Jill Medlend, U.S. Department of the Interior, National Park Service - Midwest Region, May 1990.

Minton, SA., jr. 1972. Amphibians and reptiles of Indiana. The Indiana Academy of Science. Indianapolis, Indiana.

Munson, C.A. 1980. Archeological salvage excavations at Pataka Lake, Indiana. Glenn A. Black Laboratory of Archeology. Indiana University.

National Geographic Society. 1983. Field guide to the birds of North America. National Geographic Society, Washington, DC.

National Oceanic and Atmospheric Administration (NOAA). 1965. Winds aloft summary, annual, 1960- 1964, 12 GMT from Dayton, Ohio. National Climatic Data Center. Asheville, North Carolina.

.. 1986. Imal climatological data annual summary with comparative data, Louisville, Kentucky, 1986. National Climatic Data Center. Asheville, North Carolina.

I’ctcrson, l<.‘l‘. 1980. Eastern birds. Houghton Mifflin Company, Boston, Massachusetts.

I’ublic IAW 100-526 (102 STAT. 2623). October 24, 1988. Base Closure and Realignment Act.

I’ublic law 100-526: Defense Authorization Amendment and Base Closure and Realignment Act. 1988. I.i@lative History on House Conference Report No. 100-735 (Iand 11) and No. 100-1071.

Shaffrr, Nclson R. 1981. Possibility of Mississippi Valley-type mineral deposits in Indiana. Indiana Ihpirtmcnt of Natural Resources, Geological Survey. Special Report 21. Bloomington, Indiana.

Stdlhml, I!., 11. I Insscn, E. ]elks, K.L. Barr, E. Hajic, N. Asch, and I). Asch. 1985. An Archeological ov(wiiBw and management plan for thc Jefferson Proving Ground, Jefferson, Jennings, and l

Stcgncr, Gary. 1989. Personal communication, Gary Stegner, Jefferson Proving Ground, Public Affairs Ofkc*,Madison, Indiana, September 18, 1989.

9-4 ‘I’ll(, l’rcsident’s Economic Adjustment Committee. 1978. Communities In Transition: Community I

‘fhom, I’D. and W.E. Wilson. 1967. Jefferson County history by high school students. Loaned to Indiana Historical Society Library and the Indiana State Library Indiana Division, Brazil, Indiana.

US. Army Corps of Engineers, Louisville District and Michael Baker, Jr., Inc. 1988. US. Army Jefferson Proving Ground: Mobilization Master Plan Report. Prepared for US.Army Corps of Engineers.

US. Army Corps of Engineers, Louisville District. 1989. Transcript of Public Scoping Meeting Held 8 June 1989: Citizen Input for the Closure of Jefferson Proving Ground. Louisville, Kentucky.

U.S. Army Corps of Engineers, Los Angeles District and Sharon Clark Associates, Inc. 1989. Yuma Proving Ground Proposed Consolidation Public Scoping Meeting. Prepared for US.Army Corps 01 Engineers.

US. Army, Department of Defense (DOD). December 1988. Report of the Defense Secretary’s Commission: Base Realignment and Closures. Washington, DC.

U.S. Army Engineer Institute for Water Resources. 1989. Appendix 11: The Economic Forecast System (as extracted from CERL Research Laboratory Technical Report N-127, 1982, The Two Tier Concept for Economic Analysis: Introduction and User Instruction). Fort Belvoir, Virginia.

US. Army Engineer Institute for Water Resources (IWR). 1989. Phase I1 SEA Report: Socioeconomic Impacts at Jefferson Proving Ground. Fort Belvoir, Virginia.

US. Army Engineer Institute for Water Resources (IWR). 1989. Phase I1 SEA Report: Socioeconomic Datacall Major Command Responses for Jefferson Proving Ground Related BRACO Actions. Fort I3clvoir, Virginia.

U.S. Army linvironmental Hygiene Agency (USAEHA). 1983. Environmental noise assessment spwial bludy No. 52-34-0492-83, noise contours for existing operations and operational alternatives, ]i,flcrson I’roving Ground, Madison, Indiana. Prepared for USAEHA, Aberdeen Proving (;round, Maryland.

~. 1983a. Special Study No. 17-44-024&84, Environmental Impact of Pesticides Use, Jefferson I’roving Ground, Madison, Indiana. Prepared for USAEHA, Aberdeen Proving Ground, Malryla nd.

1J.S. Army ‘l‘est and Evaluation Command (TECOM). 1978. US. Army Jefferson Proving Ground ~~nvironmentalimpact assessment, Madison, Indiana.

~ . 1980. Environmental impact assessment, US. Army Jefferson Proving Ground. l’rcpared by John E. ONeill, Installation Environmental Quality Coordinator.

- 1989. JPC Base Realignment and Closure Plan. Headquarters, Aberdeen Proving Ground, Maryland. Plans, Analysis & Evaluation Office. August 1989. .

9-5 U.S. 'l'oxic and I iazardous Materials Agency (USATHAMA). 1980. Installation assessment of Jefferson I'niving Ground Report No. 176. August 1980. Prepired USATHAMA, Installation Restoration I >ivision, Aberdwn l'roving Ground, Maryland.

~-~- . 1989. Enhanced Preliminary Assessment Report: Jefferson Proving Ground, Madison, Indiana. Prepared by Environmental Science and Engineering, Inc. for USATHAMA, June 1989. Aberdeen Proving Ground, Maryland.

__ ___ . 1990. Enhanced Preliminary Assessment Report: Jefferson Proving Ground, Madison, Indiana. Prepared by Ebasco Environmental for USATHAMA, March, 1990. Aberdeen Proving Ground, Maryland.

US. Department of Agriculture (USDA). 1978. Classification/Enhancement of LANDSAT digital data. Letter report prepared by General Electric Company, Beltsville, Maryland.

-~ -__ . 1985. Soil survey of Jefferson County, Indiana. Soil Conservation Service in cooperation with Purdue University Agricultural Experiment Station, Indiana Department of Natural Resources and the Soil and Water Conservation Committee.

U.S. 1)cpnrtmcnt of the Interior (USDI). 1987. Explanation of species status codes used in data tmw listings. Prepared by U.S. Fish and Wildlife Service, Washington, DC.

U.S. Department of Defense (DOD). December 1988. REport of the Defense Secretary's Commission: Ilasc Realignment and Closures. Washington, D.C.

1J.S. Ihvironniental Protection Agency (USEPA) Region V. 1989. Letter to Lt. Colonel Michael B. Coliian, Louisville District COE, June 30,1989. Recommendations of the USEPA on theProposed Sccrpc of Draft EIS. Re: Closure of JPG and Realignment to YPG. Chicago, Illinois.

U.S. Ilnvironmental Protection Agency (USEPA). 1988. Musts for USTs, September 1988. Office of Underground Storage Tanks, Washington, D.C.

U.S. (;cological Survey (USGS). 1985. National water summary 1984, hydrologic events, selected water quality trends, and groundwater resources. U.S. Geological Survey, Water-Supply Paper 2275. U.S. Government Printing Office, Washington, DC.

~. 1987. Waler resources data, Indiana, water year 1987. US. Geological Survey, I n(ii'insipoiis, Indiana.

LJ.S Nudciir I

Voi*};clin,I<.W. 1Y41. Indians of Indiana. In: Proceedings of the Indiana Academy of Science. 5027- 02.

9-6 Wcbstcr, J.U. 1989. Letter from Dr. J. Dan Webster, Prof. Emeritus Hanover College, Indiana, to Selma Ihnel, Botanist, WAFORA, Inc.

Whitaker, 1.0.and J.R Gammon. 1988. Endangered and threatened vertebrate animals of Indiana: 'Their Distribution and Abundance. The Indiana Academy of Science. Indianapolis, Indiana.

Winters, John. 1990. Personal communication, John Winters, Indiana Department of Natural Resources, May 1990.

9.2 YUMA I'ROVING GROUND

Arimiia Department of Commerce, Community Development Division. 1990

Arizona Department of Health Services. 1981. Annual Reports for Air Quality Control for Arizona.

Arizona G,ime and Fish Department. 1988. Threatened native wildlife in Arizona. Phoenix.

Blake, William P. 1857. Explorations and Surveys for a Railroad Route from the Mississippi River to the Pacific Ocean. Senate Document 78, 33rd Congress, Vol. 5. Washington, D.C., Geological Report, Chapter 9.

Ihwn, D. I!. (editor). 1982. Biotic Communities of the American southwestern United States and Mexico. Desert Plants 4U-4).

Uryan, Kirk. 1922. Route to Desert Watering Places in the Papago County, Arizona. US.Geological Survey I3ullctin 490-D.

Ihircvu of IAnd Management, Yuma District. 1985. Draft Yuma District Resource Management Plan

C'aliforiua Air Resources Board. 1985. Summary of 1985 Air Quality Data: Gaseous and Particulate I'dlutants. Vol. 17.

Cxnp 1Irossc.r and McKee, Inc. 1988. Hazardous Waste Management Report: Audit of Target l~~icilitics,USA Yuma Proving Ground, Yuma, Arizona.

C'urtib, I:dward S. 1907. The North American Indian (Vol. 2), edited by Frederick W. Hodge. Nurwood: I'limpton Press. ti,, Vos, Jaiiws C. Jr. and William D. Ough. 1986. Yuma Proving Ground East Wildlife Inventory. Arizona Came and Fish Department. Prepared for US.Army Yuma Proving Ground.

lifll,iiid, l

9-7 litfl.inii, Kichnrd W., Allan I. Schilz, Joyce Clevenger, and Elizabeth H. Stein. 1986. Archeological Iiivestig;ilions on the Yuma Proving Ground. Sample Survey of the Cibola Range, An Asscssmcwl of Cultural Kesource Sensitivity in the Western Deserts of Arizona. Reported Iircpar'cd by WSTEC Services, Inc. for the US. Army Corps of Engineers, Los Angeles District.

Iilflund, Richard W. and Allan J. Schilz. 1987. Archeological Investigations on the Yuma Proving Ground: Survey and Evaluation of the Laguna Amy Airfield. Report prepared by WESTEC Scrvices for the US. Army Corps of Engineers, Los Angeles District.

Elling, C. Michael and Jerry Schaefer. 1988. Archeological Investigations on the Yuma Proving Ground: A Survey of Lithic Quarries and Chipping Stations in the North Cibola Range. Report prepared by Brian F. Mooney Associates for the U. S. Army Corps of Engineers, Los Angeles District.

Emory, W. H. 1848. Notes of a Military Reconnaissance from Fort Leavenworth in Missouri to San Diego in California. Washington: Wendell and Benthuysen.

Farrell, Nancy. 1984. Cultural Resources Survey of the Proposed Direct Fire Weapons Ground, Arizona: Preliminary Report. Ms. on File, U.S. Army Corps of Engineers, Los Angeles District.

I;ordc, C. Daryll. 1931. Ethnography of the Yuma Indians. University of California, Publications in American Archeology and Ethnology 28(4):83-278.

Gifkird, E.W. 1Y33. The Cocopa. University of California, Publications in American Archeology and litlmology 31 (5):257-334.

Ciflord, E.W. 1936. Northeastern and Western Yavapai. University of California, Publications in Aincricaii Archeology and Ethnology 34(4):247-354.

I Iaydcn. Julian D. 1967. Summary Prehistory and History of the Sierra Pinacate, Sonora. American Antiquity 32:335-344.

-~ ~ ~ ~~ . 1976. Pre-altithermal Archeology in the Sierra Pinacate, Sonora, Arizona. American Antiquity 41:274-289. f Icrinnnn %illgens Associates. 1983. Analytical/EnvironmentaI Assessment Report, Yuma Proving <;round, Arizona. (AR210-20). Master Planning, Engineering Plans and Services Division, l%cilities I?nginecr Directorate, Yuma Proving Ground, Arizona.

I Ii};~;inb~~~li~i~iiand Associatcs. 1978. Installation Environmental Impact Assessnient for United Slatcs Army Yuma Proving Ground, Yuma, Arizona. Department of the Amiy, Materiel Develo~nicnt .lid Ihdiness Command, Test and Evaluation Command.

I Iof(nidii, 'l'ercsa 1. 1984. Cultural Resources Overview and Management Plan for the Yuma Proving (;round. Report prepared by Soil Systems, Inc. for USDI, National Park Service and the US. Army Materiel Development and Readiness Command.

Institute For Defense Analysis (IDA). 1990. Analysis of Realignment of Jefferson Proving Ground Mission to Yunia Proving Ground. Special Report.

9-8 Kelley, William H. 1977. Cocopa Ethnography. University of Arizona, Anthropological Papers, 29.

Krwber, Alfred L. 1925. Handbook of the Indians of California. Bureau of American Ethnology, Ihlletin 78.

Mann, Timothy. 1983. The Yuma Proving Ground Archeological Surveys 1982-1983. Ms. on file, 1;acilities Engineer Directorate, Yuma Proving Ground, Yuma, Arizona and Bureau of Land Management, Yuma District Office.

McCuirc, Randall H. and Michael 8. Schiffer (editors). 1982. Hohokam and Patayan. Prehistory of Southwestern Arizona. New York Academic Press.

Morallo, Michael I. 1975. On the Concept of Archeological Significance. Paper presented at the annual northern California meeting of the Society for California Archeology, Fresno.

Olmsted, F. H., 0.1. Loeltz, and Burdge Irelan. 1973. Geohydrology of the Yuma area, Arizona and California. US. Geological Survey Professional Paper 486-H.

Ough, William D. and James C. de Vos Jr. 1984. Draft report of Yuma Proving Ground Wildlife habitat resources survey. Arizona Game and Fish Department. l'alnier, Bruce. 1986. Special Status Species Summary Report. Arizona Game and Fish.

Rogers, Malcolm. 1939. Early Lithic Industries of the Lower Basin of the Colorado River and Adjacent Dcscrt Areas. San Diego Museum Papers 3.

~~ 1Y58. San Dieguilo Implements from the Terraces of the Rincon-Pantano and Rillito I)mitiage System. The Kiva 241-23.

~. 19h6. Ancient Hunters of the Far West. San Diego: The Union-Tribune Publishing c "nlpJny.

Schclvr, Jerry. 1988. Delivery Order No. 0007-Yuma Proving Ground, TEXS North Cultural Resources Irivcntory. Lclter report by Brian F. Mooney Associates to the US. Arniy Corps Of Engineers.

-~ . lY89a. A Cultural Resources Records Search of the Yuma Proving Ground. Prepared by th~,hian F. Mooney Associates for the US Army Corps of Engineers, Los Angeles District.

1989b. llunter-Gatherer Settlement Patterns on the Cibola Direct Fire Weapons Range, YiIriia I'roving Ground: Results of a Stratified Random Sample Survey. Prepared by the Brian I;.Mooncy Associates for the US. Army Corps of Engineers, Los Angeles District.

9-9 %li,icafcar, Jwryand J~li~iR. Cook. 1988. Results of Three Surveys on llie Yumn Proving Ground: Red l)liiff, OIK)l>, illid Dircvl Fire W~~aponsIhrgc. Keporl prepiwd by I)ri.rn I;. Mooncy Associ.itcs lor 11ie US. Army Corps of Enginecrs.

.kliilz, Allan J. and Joyce M. Clevenger. 1985. Archeological Investigations on the Yuma Proving (;round: the Dirwl Fire Weapons Range, Phase 1. Report prepared by WESTEC Services, Inc. lor Lhc US. Army Corps of Engineers, Los Angeles District.

%hili., Allan I., Richard L. Carrico, and Jay Theken. 1984. Archeological Investigations in Southwestern Arizona: the APS Yuma 500 kv Transmission Line. Report prepared by WESTEC Services, Inc.

Schroeder, Albert H. 1952. Brief Survey of the Lower Colorado River, kom Davis Dam to the International Border. National Park Service.

. . 1974. Study of Yavapai History. In Southwest, Vol. 9, edited by Alfonso Ortiz, pp. 100- 107. Handbook of North American Indians. Washington, D.C.: Smithsonian Institution.

Silgreavcs, Lorenzo. 1853. Report of an Expedition Down the Zuni and the Colorado Rivers in 1851. U.S. Sen. Ex. Doc. 59,. 32nd Congress, 2nd Session, 1853.

Spirr, I.(4ic. 1933. Yuman Tribes of the Gila River. Chicago: University of Chicago Press.

Swarthit, Jeanne and Christopher E. Drover. 1981. Final Report for an Archeological Overview for (lie Lower Colorado River Valley, Arizona, Nevada, and California. Reach 3. Davis Dam to the International Border. Report prepared by the Museumof Northcrn Arizona for theUSDl Bureau of Iklamation.

Tlitmias, Alfred B. 1974. The Yavapai Indians 1582-1848. In Yavapai Indians, edited and compiled by Ihvid Agec Horr, pp. 355-386. New York and London: Garland Publishing, Inc.

U.S. Army. 1983. Analysis of Existing Facilities Environmental Assessment Report - Yuma Proving (;round. (AR 210-20), Eng. Dept. 126(R3).

U.S. Army Corps of Engineers, Los Angeles District and Michael Brandman Associates, Inc. (USACE-LA and MUA). 1987. Final Environmental Assessment: United States Army, Yuma Proving Ground. I’reparcd for U.S. Army Yuma Proving Ground.

11.5. Arriiy Corps of Engineers, Los Angeles District and US. Army Yunia Proving Ground (USACE-LA aiid USAYI’G). 1987. Installation Natural Resources Management Plan Update, U.S.Amy Yuma Proving Ground, Yuma.

US. Army Corps of Engineers, Los Angeles District (USACE-LA). 1986. Hydrology for Contaminant ‘l’ransportStudy at the Cibola and Kofa Firing Ranges, Yunia Proving Ground (YE), Arizona.

U.5. Army Tcixic and Hazardous Materials Agency (USATHAMA). 1980. Installation Assessment of Yuma Proving Ground Report No. 139. .

9 - 10 -. 1988. Update of the Initial Installation Assessment of Yuma Proving Ground.

U S Department of Agriculture, Soil Conservation Service. 1974. Report and Interpretations for the Geiwral Soil Map of Yuma County, Arizona.

Wirlh Associates, Inc. 1980. Appendix A. Arizona Public Service/San Diego Gas and Electric Inlercoiuwrtion Project Environmental Study, Phase Two Corridor Studies. Archeological I

9-11 CLOSURE OF JEFFERSON PROVING GROUND INDIANA AND REALIGNMENT TO YUMA PROVING GROUND ARIZONA

.Y... Pravlm VOLUME 2 OF 2 -.____m.... 1 APPENDICES Final ENVIRONMENTAL IMPACT STATEMENT September 1991 APPENDIX L

PHOTOGRAPHS OF UNEXPLODED ORDNANCE AT rpG

APPENDIX M

COMMENTS AND RESPONSES ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT

FOR

CLOSURE OF JEFFERSON PROVING GROUND, INDIANA AND REALIGNMENT TO YUMA PROVING GROUND, ARIZONA PREFACE

Public Law 100-526 placed into law the recommendations of the 1988 Base Realignment and Closure Commission. The Commission recommended the closure of JPG and realignment of the Production Ammunition Acceptance Test Mission to YPG. "Closure" as it relates to this action, means the discontinuation of operations in preparation for the time-phased realignment to YPG.

Under the Base Closure Law, the DOD is exempted from certain NEPA provisions. DOD does not have to address alternatives to closing JPC or realigning the JPG production acceptance testing mission to YPC. The Commission also recognized the need to separate the closure analysis and decision-making from the remediation when it stated "Cleanup is independent of closure" (DOD1988). This EIS, therefore, analyzes only the potential environmental impacts associated with closure of JPG and realignment to YPG. It does not analyze future reuse or contamination remediation measures.

The decision-making related to JPG is sequenced into three steps. This EIS analyzes and forms the basis of a decision regarding the impacts of closure of JPG and realignment of functions to YPG. Separate NEPA analysis and documentation will be tiered from this analysis, and will analyze potential reuse alternatives and their associated impacts. The JPG Regional Development Board and public will play a significant role in developing these alternatives. A Remedial Investigation/Feasibility Study (RI/FS)will be developed in consonance with the reuse analysis to identify and evaluate remediation measures required for implementing the preferred alternatives. These three separate, yet related processes will facilitate public involvement and decision-making rclatcd to closure, reuse, and remediation.

The general reuse options provided in the EIS represent preliminary coordination with the Regional Development Board and others. Reuse alternatives are not yet sufficiently developed to make a dcyision. The Army will continue to coordinate with the JPG Board and the public in scoping and development of the follow-on reuse NEPA analysis and documentation. This follow-on analysis will help form the basis of a decision regarding reuse of JPG.

Keuse planning and remediation are interrelated processes. Additional remediation studies bc:yond the Preliminary Assessment will be conducted by the Army in parallel with the follow-on rcusc analysis. An RI/FS and cleanup will be conducted on the 3,000 acres south of the firing line. A site-specific sarnpling/anafysis plan including surface water from all surface streams traversing JPG, and groundwater samples from groundwater monitoring wells located at an impact field in JPG's mirth area will he implemented. The RI/FS will include field testing to define the nature and extent of ont*iniiiiation in this area. It will also provide the opportunity for the public to participate in idciitifying environmental issues and evaluating alternatives before a remediation decision is made. hhlic involvement in the Rl/E process is supported by news releases, public meetings, and reviews. At the conclusion of the RI/FS, a proposed plan will be prepared to summarize-the cleanup iiltcrnntivcs, and to identify the preferred alternatives and reasons for their selection. The RI/E Kword of Dwision will document the action to be taken.

. SOUKCliS OF I'UBLIC COMMENTS

111 accordance with NEPA, CEQ guidelines, and AR 200-2, the Draft EIS was made available for public rcvicw from May 24, 1991 through July 8, 1991. Copies of the EIS were provided to agencies, [)r~~'ii~i~'iti(~iis,and individuals listed in Chapter 7. Comments on the Draft EIS were received by letter %intiduring piihlic meetings held in Yuma, A2 for YPG on June 19, and in Madison, IN for JPCon June 24, lY91.

ORGANIZATION OF APPENDIX M

Responses to comments received are presented first for JPG, followed by WG. The order of presentation is as follows: 1) written comments and responses concerning JPG, 2) oral comments made during the JPGpublic meeting with responses, 3)photocopies of letters received, and 4) transcript of the public meeting. The same order is kept for presentation of the WG public review. Both JPGand YPG coniinents are identified in the same manner, as described below.

1,cttcrs were generally numbered in the chronological order in which they were received. Each letter was numbered in the upper right hand comer. Within each letter or statement, issues are identified by a vertical bar marked along the left hand margin of the text and numbered in sequence for that individual letter. The comments are reiterated and responded to in the order in which they appear in the letter. Thus the comments are numbered, for example, 1-1 for letter 1, comment 1.

Comments made during the public meetings are also numbered in sequential order and issues arc marked with a vertical bar in the left hand margin of the transcipt text. The speakers are numbered in tlic order in which they spoke. These numbers are marked in the right hand margin of the transcript.

A list of all letters received, all speakers, and their assigned numbers is presented at the beginning

(I[ ttw JlC response to comments and YPG response to comments, respectively. Jefferson Proving Ground List of Letters Received (All Dates are 1991)

I I lonorable Lnr Hamilton, May 21.

-.3 Glenn D. Murphy, June 13

3. US. Department of Transportation, Federal Highway Administration, May 31.

4. Mr. Ken Knouf, June 24.

5. Senator Lugar and Senator Coats, Juune 17.

6. Senator Lugar statement presented at Madison Indiana Public Meeting, June 24.

7. Senator Coats statement presented at Madison Indiana Public Meeting, June 24.

8. Representative Hamilton, statement presented at Madison Indiana Public Meeting, June 24.

9. Hoosier Environmental Council Resolution presented at Madison Indiana Public Meeting, June 24.

10. William H. Sage comments presented at Madison Indiana Public Meeting, June 24.

11. American Federation of Government Employees statement read at Madison Indiana Public Meeting, June 24.

12 Mr. Mike Moore, JPGSurvival Committee, statement read at Madison Indiana Public Meeting, June 24. z 13. Indiana Dept. of Natural Resources, Division of Outdoor Recreation, July 3.

14. John 0"eill (copy of document), June 12.

15. Airspace Management Branch, National Guard Bureau, June 24.

I(?. Mike Moore, June 26.

17 JSiiiicsA. Uozin, Tcclinical Manager, June 27

I 8. Madison Industrial Development Corporation, July 1.

I C) IiSSI, July Et.

20. Senator Conts, June 27. JeffersonProving Ground List of Letters Received (Concluded) (All Dates are 1991)

21. Daryl Kams, Hanover College, July 5. 22. Department of Health and Human Services, June 28.

23. Arthur B. Alphin, july 2.

24. Evan Bayh, Governor of Indiana, July 5.

25. Indiana Department of Environmental Management, July 9.

26. National Toxics Campaign Fund, July 9.

27. Mr. Sierps, Citizen, summarized from audio tape, July 10.

28. United States Environmental Protection Agency, )illy 15. JEFFERSON PROVING GROUND COMMENTS AND RESPONSES CONCERNING THE DEIS

1 HONORABLE LEE H. HAMILTON

1-1 I am well aware that the EIS is not intended to review actions or impacts associated with potential rcmdiation activities. But it seems to me that the UXO problem lies at the heart of the matter. The single greatest environmental impact of this closure is the creation of a 55,264 acre hazardous waste site outside of Madison, Indiana. I am very surprised to read in the draft EIS that closing the base will have beneficial environmental impacts (as the Army will no longer add to the contamination at the base). The future of this property hinges on how and whether the Army intends to assess and clean up the UXO contamination.

KLSI’ONSE: This EIS focuses on the mission transfer aspects of the BRAC action rather than specific aclions or impacts associated with potential remediation and reuse activities at JPG. Hazardous inaterials are discussed to the extent that they affect or are affected by closure or realignment (Section 2.2.4). The Army is committed to meeting requirements concerning environmental regulatory compliance. Prior to the disposal of any property at JPG,the Army is committed to ensuring public health and safety. The Army will conduct a Remedial Investigation/Feasibility Study (RI/FS)on the area of JPC in the cantonment area and clean it up. In addition, an RI/FS will be performed on any other area prior to releasing that property from DOD control.

I‘he discontinuation of testing activities is considered to be a beneficial rather than negative environmental impact at JPC because no new contamination caused by the firing of additional ordnmce will occur. Theclosure of JPG will not change the potential for contamination from existing UXO As is stated in Section 1.4.4.6, the past usage and disposal of hazardous materials and UXO will have a long-term impact, and the level and extent of this impact is unknown. The Army will implement a sampling program of selected sites and all streams to determine if contamination is prcscnl in concentrations that would be hazardous to the human health or the environment.

1-2 Second, I am also displeased that the Army will not study, let alone clean up, UXO contamination iiorth of the firing line.

1-3 C’lcdrly, the presence of UXO contamination over the entire base poses a long-term health risk to thc hiitroiiiidiirg population and environment. And yet, the Army’s policy is not even to study the CIXO prohlcm north of the firing line. How can you justify this policy? I1ESPONSE The Army will implement a sampling program of selected sites and streams to deterinine if contamination is present in concentrations that would be hazardous to human health or the environment. The site specific sampling and analysis will include surface and sediment samples from all the surface streams that traverse JPG. Groundwater samples also will be collected from groundwater monitoring wells that exist at an impact field (JI‘G’s north area). These samples will be analyzcd for UXO chemical constituents (including heavy metals), pesticides and uranium isotopes. All areas having a significant risk will be remediated in accordance with law. Cleanup and reuse will be addressed in future environmental analyses and documentation under the provisions of NEPA.

1-4 At the very least, the Army should conduct an extensive study of the contamination problem north of the firing line. The Army claims that it does not have cost-effective technologies to clean up the entire base at this point, but certainly has the capability to prepare a comprehensive RI/FS of the entire base. An RI/FS would at least give the Army and the residents of southern Indiana an accurate assessment of the scope of the contamination, and a summary of potential remediation strategies.

IUX’ONSE: Regulations require that, when performing an RI/FS, UXO will be cleaned up as it is encountered. Cleanup of UXO north of the firing line is not feasibleat this time. An RI/FS in that area will be performed when the Army has the technology.

1-5 Third, I am concerned about the Army’s commitment to clean up the 3,000 acres south of the firing linc. What troubles me is that the Army has made no commitment to actually clean up the conlainination south of the firing line.

KESI’ONSE: The Army intends to remediate (cleanup) contaminated areas in the 3,000 acres south of the firing line. The FS (Feasibility Study) portion of the RI/FS involves determining the best way to cleanup such contamination. All areas having a significant risk must be remediated in accordance with laws and regulations.

1-6 I would like more assurance from the Army that it will proceed with the cleanup, even with this (ntrmcrous environmental problems) contamination problem.

1-7 I a~;rcethat a govrmnient-owned, contractor-operator (COCO)or lease arrangement has merit. It w(iuld not entail a significant change from current operations at the base, and might remove the pIobk~ti~of ordnance cleanup. However, the Army has been reviewing this alternative far some time, .ind Iins raised concerns that it might not comply with the provisions of the 1988 Base Closure Act. St.c.t

1-8 I trust that the Army will study this proposal (air facility reuse option) more vigorously.

RESPONSE: Reuse will be studied by the JPG Regional Development Board in conjunction with the Army and Office of Economic Adjustment. The uncertainty of the final disposition of JPG makes it inipossible to prepare a detailed environmental analysis of the ultimate reuse, including the possibility of (he air facility option. This EIS is not intended to provide a complete analysis of detailed final reuse plms. Rather, it identifies and evaluates a number of broad reuse concepts and the general feasibility of these concepts. The reuse plan ultimately developed for JPG will be the subject of separate NEPA analysis and documentation prior to the final disposal of property at JPG.

1-9 How can the Army pursue these alternatives (regional landfill and/or a correctional facility) if it has no intention even to study the UXO problem north of the firing line? I think the Army should clarify its position on this issue.

KESPONSE: See response to comment 1-8.

1-10 Fifth, I am concerned that the "caretakerstatus"proposedfor the base will become permanent.

1-11 I am left with the distinct impression that the Army is looking for the most inexpensive way of ilisposiiig of Ihe JPC property, even if this means putting the facility in "indefinite standby status." I'lw Army has committed $5-6 million for the RI/FS on the cantonment area. It has committed to do iiotliiq; iiiore than that. It seems content to fence off the property and pay the bare minimum for uphct,j' iind maintenance of the facility, at least for the indefinite future. Under this arrangement, the

\I1(; property would be of no use to anybody -- the Army, the state, and local publicand private inl{.rc\ls. 'I'his would be the worst possible solution. RESPONSE: This is not the Army's intent. At this early stage, a reuse policy has not been developed regarding ultimate disposal of property. Further study and analysis is planned to develop viable riwse options.

2 MIL GLENN D. MURPHY, LETTER OF JUNE13,1991

2-1 JI'C, while open and operating, meets all environmental requirements; once JPG is closed, does not unexploded ordnance (UXO) become classified as hazardous waste and immediately become a tremendous adverse environmental impact for which there is not current solution?

RESPONSE: The closure of JPG does not affect the status of unexploded ordnance (UXO).

2-2 The statement, "No additional environmental contamination will result due to the closure of JPG does not appear to be true when one considers the above comment (2-1) and the fact that additional contamination will occur at YPG when testing begins there.

RESPONSE: The statement that no additional environmental contamination will result was meant to apply to JPG. This is now clarified in the text. The discontinuation of testing activities at JPG is considered to be a beneficial rather than negative environmental impact because no new contamination caused by the firing of additional ordnance will occur there. Additional contamination will be minimized to the extent possible.

2-3 The $30.4 million is WG's one time costs. There is an apparent omission of $23.3 million in JPG's estimated one time expenditures. Rightfully including JPG's one time costs makes the total realipment cost $136.3 million (see encl I).

ICESI'ONSE: The executive summary has been corrected. The estimated cost of facility construction is $82.2 million. The estimated one time expenditures for JPG and YPG is $50.04 million which would result in a total realignment cost of $132.24 million.

2-4 Over 19,000 person-days of recreation (not counting deer hunting) will be lost annually which in my opinion is not negligible. Following is a listing of CY 90 JPG recreation person-days... As long as ]IT is in caretaker status, all recreation activities should be continued for JPG active and retired l~lnpl~lyces.

KESI'ONSE: The listing of recreation person-days has been changed to reflect your concern (Section J 0.4.5.12). t lowever, because there are many recreation opportunities in the ]IC vicinity, the impact of churcis not considered to cause a significant negative impact. Allowing JPG active and retired t.rnp1uycc.s rccrcation privileges after closure has not been determined. 2-5 Jl'C's personnel costs are currently estimated at $13.2 million dollars by TECOM. One-time expciiditures for JPC are currently estimated at $23.3 million dollars which are excluded from the EIS. (see encl 1).

RESPONSE See response to comment 2-3.

2-6 I do not believe the decision to close JPG was based on sound accurate data. The EIS should contain all accurate applicable data.

RESPONSE: The decision to close JPG was made and enacted as law as a result of the Defense Secretary's Commission on Base Realignment and Closure, and the Base Closure Realignment Act. The Act precludes the requirement to evaluate the decision to closeJPG.

3 US. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION, LETTER OF MAY 31,1991

3-1 It has been determined that the proposed closure will not adversely impact highways and therefore, have no comments to offer on the draft EIS.

RESPONSE Comment noted; no response is required.

4 KEN G. KNOUF, LETTER OF JUNE24,1991

4-1 Table S-2: Public safety should be added as a factor. Long term public safety will be in jeopardy if the range area is not cleared of unexploded ordnance.

KESI'ONSE: Table 52as been revised to reflect the addition of Public Safety as a factor of concern. The pcrimcter fence will be secured and maintained to prevent public access and off-post land use cmcrmchmcnt, preserve public health and safety, and protect government property from illegal entry aid vandalism. Public safety service areas for security and fire protection will also be required.

4-2 As it appears that maintaining JPC in a caretaker status becomes more and more of a realistic outcoine, requirements and staffing needs should be addressed and this section expanded. Assuming tlic c.irl%>kerstaff to be existing JPG workforce personnel, this staffing determination should be iiiwrpor'ittd into Table 2.2-1 (pg. 2-8,2-9).

I1ESI'ONSE: Caretaker staffing levels will be determined during closure as specific needs are

idtm t il icJ . 4-3 I’lnns to conduct a remedial investigation/feasibility study for the south end only is unacceptable. We cannot ignore the area north of the firing line.

ItESI’ONSE: See response to coninients 1-3and 1-4.

4-4 I

RESPONSE: The regional landfill alternative considers locating a site of significant size with the proper geophysical properties. The landfill alternative would require investigation and assessment to detemiine the extent of unexploded ordnance contamination. Moreover, siting of such an alternative would require an investigation and assessment of all significant natural, geophysical, and cultural resources. Soil types and the location of various natural resources may restrict this alternative from the iiorthwestern section of the property. Reuse alternatives and associated impacts will be addressed, in a more detailed manner, in future NEPA analysis and documentation.

4-5 Regarding the Correctional Facility option, why not locate it in the existing industrial area which already has the infrastructure necessary to support this kind of facility. This would be preferable to the northeast portion which contains abundant recreational, wildlife, timber and scenic qualities but little development. Has anyone given any thought to combining a job training facility with a low security correctional center? JPG would also make a good Job Corps Center. These kinds of facilities would help offset the loss of jobs and provide skilled JPG workers with employment opportunities.

ItESI’ONSE: As in the previous alternative, the correctional facility would require investigation and assessment to determine the extent of unexploded ordnance contamination. Siting of such an alternative would require an investigation and assessment of all significant natural, geophysical and cultur;il resources. Location of various natural resources may restrict this alternative from the northcwtern section of the property. Since no other details regarding this alternative have, been devt.lopcd, further evaluation is warranted. The uncertainty of the final disposition of JPC makes it iinpossiblc. to prepare a detailed environmental analysis of the ultimate reuse for this document. This I(IS is not intended to provide a comprehensive analysis of detailed final reuse plans. The document siniply identifies and evaluates a number of broad reuse concepts and the general feasibility of these coiicc,pts. ‘l’liereuse plan ultimately developed for JPC will be the subject of separate NEPA analysis .ind dociinientation. Details regarding the job training facility and a Job Corps Centqr have been IWkd. 4-6 Terrestrial Ecology: While it is true that JPGk unexploded munitions contamination has precluded much of the installation from being inventoried, there is an opportunity to apply GIS and CRASS in helping to analyze the installation. There is no evidence that GRASS was used in any portion of the EIS.

4-7 Where fox is mentioned, this should be fox squirrel. While we have both red and gray foxes, both arc relatively rare. Fox squirrels are abundant and squirrel hunting is very popular at JPG.

RESPONSE Section J.3.1.8.1 has been revised to reflect this change.

4-8 l>esipated mast producing trees remain uncut to provide food for wildlife. However, hickories, oak and beech are cut when timber harvests are conducted.

ItESPONSE: Section J.3.1.8.1 has been revised to reflect this change.

4-9 Birds: Due to favorable habitat conditions, JPG supports an abundant population of bluebirds and two bluebird trails have been created.

RESPONSE: lnformation regarding the JPG bluebirds has been added to the section regarding birds.

4-10 So as to not to cause confusion about Graham Creek not being in Jefferson County, Professor Karns included the herpetological survey so as to provide continuity in his assessment of species diversity.

4-11 Again, the discrepancies in our woodland acreage points out the need for GIS and GRASS implementation. However, our estimated acreage of forestland is increasing not decreasing as old fields revert to sapling stands.

K1:Sl’ONSE: See response to comment 4-6. The estiiiiated acreage of forestland has been revised

‘IC< (11 dl1l~;ly

4-12 Undcr I.~ndmmagcment practices, JI’C does little seeding or planting after prescrib2d burning. NCIIIII.III~, ,i v,iriety of native and exotic vegetation come up quickly and do provide wildlife browse. IWSPONSE: Information regarding the reseeding of vegetation after prescribed burning has been revised to reflect the change.

4-13 Unfortunately, JPG lost our funding for an endangered plant survey. Consequently, there are no immediate plans by the IDNR to conduct any type of survey.

RESPONSE: Funding was recently approved for an endangered plant survey to be conducted by the Indiana State Nature Preserves, Division of IDNR. The Army will prepare a Natural Resources Management Plan that will address threatened and endangered species, species of concern, wetlands and other resources at JPC. This plan will comply with 32 CFR 65 and all other applicable laws. A scdimentation and erosion control plan will be prepared and implemented. Timber management will be addressed in the Natural Resources Management Plan.

4-14 On the wetland acreage, since Old Timbers Lake amounts to approximately 165 acres, the 108 acre lacustrine figure leads one to question the overall accuracy of the acreage figures. Again, GRASS might help to provide more accurate data on wetlands at JPG.

HESPONSE: See response to comment 4-6. Lacustrine wetland acreage values have been revised to reflect your concern.

4-15 I suggest adding D Road and the John Hunt Morgan monuments to the map on pg. 3-42. This is the route Morgan’s Raiders took during the Civil War.

RESI’ONSE: The map and text were revised to reflect your concern.

4-16 Oakdale School has been nominated to the National Register of Historic Places. We are currently awaiting the decision of the SHM).

KESPONSE: Section 1.3.4.3.2was revised to reflect this change in status

4-17 The state lottery system where a few drawn deer and turkey hunters are permitted to access JPG is subject to conditions specified in the MOA and does not involve fishing. DOD employees outside ]IC are generally not permitted recreation privileges on post however, active duty and retired military personnel do have recreation privileges.

KESI’ONSL Section J.3.4.5.12has been revised to reflect the change . 4-18 In IWO, ;I waterline was construckd in the north end, supplying waler to Old Timbers Lodge. ]I1(: pitrc‘hnscs this water from the Canaan Water Company (pg. 3-68). I

4-19 The unexploded ordnance situation at JPG should be the major focus of any further planning. With ]PG’s tremendous natural resource base acting as an “attractive nuisance“, it is certain that curious trespassers and poachers will illegally enter the installation. Someone will get hurt or die if security cannot be maintained.

IESI’ONSE: The perimeter fence will be secured and maintained to prevent public access and off- post land use encroachment, preserve public health and safety, and protect government property from illegal entry and vandalism.

4-20 Cessation of the mission and ending of the prescribed burning program will also be adverse to the hobwhite quail population. Natural succession will result in more niaple/sweetgum stands which have minimum wildlife value.

KESI’ONSE Section 1.4.1.8.1 has been revised to reflect this additional information. See response to comment 4-13.

4-21 Under Land Use, it would appear that maintaining JF’G in a caretaker status does not comply with the original legislation. The law said that the land was to be disposed yet there is little chance this will occur. How can this selective interpretation be rationalized (pg. 4-11)?

4-22 My overall comment is that while the DEE adequately documents JPG’s resource base as best as we currently know, it does reflect a general lack of understanding and awareness. How can we truly discuss impacts if we really do not know the resources nor what the plan really is?

I~ESI’ONSE: ’l’hc Army has made every reasonable effort to ensure that the EIS analysis and dorunicntation is complete, accurate and legally sufficient. Revisions have been made to the douimcnl in rcsponse to comments received from the public and environmental agencies during the coiiinicBnt period for the Draft EIS. The EIS has been prepared in compliance with P.L. 100-526 and NIiI’A. 5 KICHARD G. LUGAR, UNITED STATES SENATOR AND DAN COATS, UNITED STATES SENATOR, LETTER OF JUNE 17,1991

5-1 We have previously explained our displeasure that the Department of the Army had confined the current remedial investigation/feasibility study (RI/FS) to the cantonment area which comprises less than 3000 acres or 5% of the installation’s 55,264 acre site. The cantonment area south of the installation’s firing line will receive an RI/FS which will be completed prior to a reutilization decision. Substantial reutilization of JPC requires a comprehensive evaluation of the extent and nature of unexploded ordinance which permeates the complete facility.

RESI’ONSE: This EIS focuses on the mission-transfer aspects of the BRAC action rather than specific actions or impacts associated with potential remediation and reuse activities at JPG. Hazardous matcrials are discussed to the extent that they affect or are affected by closure or realignment (Section 2.2.4). The Army is committed to meeting requirements concerning environmental regulatory compliance. Prior to the disposal of any property at JPG, the Army is committed to ensuring public health and safety. The Army will conduct an RI/FS on the area of JPG in the cantonment area and clcan it up. In addition, an RI/FS will be performed on any other area prior to releasing that property from DOD control.

5-2 We are interested in obtaining a clean-up strategy and a cost estimate for clean-up prior to the closure of this facility.

IIESI’ONSE: While a complete cleanup of the entire installation is currently infeasible, we intend to continue with the RI/FS process in the cantonment area. The culmination of this process, the knsibility Study, will provide cleanup alternatives from which we will select the most appropriate one. The extent to which contaminated property is to be cleaned and the reuse of that property are mutually dependent. The Army intends to fully clean the south area consistent with reuse requirements. Cleanup and reuse planning is an iterative process. The Army will continue to ctrtrperate with the DOD Office of Economic Adjustment and the JPG Regional Development Board in identifying potential reuse alternatives. Cleanup strategy and costs cannot be developed independent

of c~ specific reuse plan.

5-3 In addition, the Draft EIS makes a bold assertion that new contamination of soil, groundwater and s1irf.u. water resources at the facility will cease with closure. This statement is unsubstantiated and n~iyII~~SIL~.ILI the general public about the environmental impacts of over 23 million rounds of

iiiiini~kinswhich have fiillen at JIG

The site specific sampling and analysis will include surface and sediment samples from all the surface shams that traverse JPC. Groundwater samples also will be collected from groundwater inmiloring wells that exist at an impact field (JPG's north area). These samples will be analyzed for UXO chemical constituents (including heavy metals), pesticides and uranium isotopes.

5-4 We are hopeful the Department of the Army will recognize the need to complete a clean-up strategy and cost estimate at JPG for the complete facility. Such a strategy and cost estimate are important elements in identifying the true environmental impacts present at JI'G. The environmental impact of closure of JPG have not been determined in the Department of the Army's Draft EIS.

RESPONSE: See response to comment 5-2.

6 STATEMENT OF U.S. SENATOR RICHARD G. LUGAR ON JEFFERSON PROVING GKOUND DRAFT EIS, LETTER JUNE 24,1991

6-1 I encouraged (at scoping meeting on JPC) "a comprehensive accounting of the quantity, location ;ind types of environmental 'contamination' throughout the 55,000 acre site."

RESI'ONSE: See response to comments 5-1,5-2 and 5-3.

6-2 1 asked in 1989 for "a candid explanation of what we do not know" including an "attempt to estimate the quantity and location of additional contamination." The Draft EIS provides no such explanation.

RESPONSE: See response to comments 5-1,5-2 and 5-3.

6-3 Unfortunately, the Draft EIS asserts in Table 5-2 on page S5that additional contanhation to soils, grwiidwciter and surface water will cease with the closure of the facility. This is an impact of closure which has limited basis in fact. The detailed environmental data that a full Remedial Iiiv~sti~;~itioti/I:easibililyStudy would develop will confirin or deny this assertion. We need to know what Ilw Army is proposing to leave as a legacy to Indiana; we need facts not assumptions.

KESPONSE: See response to comment 5-2.

6-5 I suggested an analysis of the technology and funding available to address each "environmental liability'' identified. The Draft EIS suggests the creation of "caretaker status" and indicates the "potential for unrestricted use of JPC is not considered feasible on the basis of existing technology and rcsourcc availability". This would lead one to conclude that an indefinite timetable and availability for future resources to promote reutilization results in no reuse for the overwhelming majority of this facility.

RESPONSE: Caretaker status is not the preferred long-term use of JPG. With the help of the local community, the Army would prefer to develop a more productive reuse of the installation. The extent to which contaminated property is to be cleaned and the reuse of that property are mutually dependent. Planning for both must be an iterative process, and the Army will continue to cooperate fully with the DOD Office of Economic Adjustment and the JPGRegional Development Board.

6-6 I indicated the need for a plan to maintain appropriate security at the facility after closure has twen completed ... The personnel and budget requirements for these continued operations under "caretaker status" have not been identified:

6-7 It is clear from even a cursory evaluation of the Draft EIS that the Department of the Army has provided minimal data and analysis of the areas where over 23 million rounds of ammunition have bcen fircd over the last fifty years. The Department of the Army has provided a very limited commitment to clean-up and reutilization of 95% of this facility based upon its creation of the carrlakcr status which niothballs the facility indefinitely and provides only hope that clean-up rrsourws will be provided in an, as yet, unspecified time period.

0-8 I Ill\ (Ielcrring to comment 6-7) is simply unacceptable and an action which undermines the intent Irchind thc I3.1scClosure and llcalignnient Commission process - to reduce Defense Department base support in both number and operational support costs and to reutilize the closed facilities for the benefit of the local economies facing the base closures. These goals have not been achieved at Jefferson Proving Ground.

I(ESI'0NSE: It is outside the scope of this document to analyze the intent the Commission had in their selection process. However, as mandated by law, JPG must close. The best utilization of the closed installation will be derived from cooperation between the DOD and the JPG Regional Development Board. To that end, the Office of Economic Adjustment and planning grants were established. The Army will continue to cooperate fully with local community planning.

7 U.S. SENATOR DAN COATS, STATEMENT READ AT JPG PUBLIC HEARING, JUNE 24, 1991

7-1 The Department of Defense must take full responsibility for guaranteeing that the residents of Jefferson, Ripley and Jennings Counties are fully protected from the hazards left behind by the military. 1 urged the Corps of Engineers to fully assess those hazards and to devise a responsible plan for miligating that danger with a clean-up strategy. Unfortunately, neither the Corps of Engineers or the Department of the Army have done this. In fact, the document prepared by the Department of the Army is sorely inadequate.

RESPONSE: See response to comment 1-1. In addition, the caretaker status would provide for a fire and security protection as discussed in Section 2.2.3. The reuse plan ultimately developed for JPG and cleanup will be the subject of separate NEPA analysis and documentation.

7-2 The draft ElS does not evaluate the environmental and/or legal requirements which the Dcpcirtmcnt of the Army must meet even though it does assert the "the Army will retain JPG for an undelermined amount of time ..."

RESI'ONSE: See response to comment 4-22

7-3 The creation of "caretaker status" for JPC almost ensures non-use of a major portion of the facility. This non-use or non-utilization of substantial portions of the facility does not comply with the spirit of tlic 1988 Base Closure and Realignment Commission Act. Reutilization of the facility for economic dlwelopnient activities is of essential interest to the communities surrounding JPG.

7-4 I Ii.ive rLqiiested several photographs of unexploded ordnance from the JPG personnel for use in ~1ic*lin;il i,nvir~inmt.iilnIimpact statement. 1 am requesting that the Depnrtment of the Army include sevcral photographs of the unexploded ordnance in the final EIS in order to provide the general public with a visual description of this problem. It is a serious concern to which the Department of the Army h;is provided limited evaluation in the Draft EIS.

KESI’ONSE: l‘he photographs are included as Appendix L.

7-5 I also continue to assert the need for a clean-up strategy and cost estimate in the EIS. I believe the inclusion of this information to be substantial enhancement to the EIS.

ItESPONSE: See response to comment 5-2.

7-6 I am also very concerned that the Department of the Army has not forwarded a copy of this draft I

ICESI’ONSE The Nuclear Regulatory Commission was inadvertently left off the DEIS distribution list. ‘lhe correction has been made and they will be sent a copy of the FEIS. If NRC provides conmetits that would require a response during the 30 day FEIS public review period, they will be addressed in the ROD.

7-7 Upon closure of the facility, the Department of the Army is required to submit a plan for decontamination and decommissioning of the depleted uranium license issued under the authority of the Atomic Energy Act. Although brief mention of this process is made in the draft EIS, no timetable, cost estimate or strategy for complying with this requirement is made.

IWSI’ONSE: The Army recognizes the seriousness of the DU concerns at JPG. A decommissioning plan will be submitted to NRC which specifies how DU contamination will be cleaned up and to what extent. See also Section J.3.4.6.

7-11 I lie costs for clean-up are substantial, however, I believe the Department of the Army has .icknowltdgc~dresponsibility for the facility and its acknowledgement should be combined with a rcwlili/,ilion pl‘iti that broadens the proposed uses beyond a correctional facility, general aviation .iirport ,ind/or regional landfill.

15 considc-rcd ii loiig-term process. The broad reuse concepts presented in the EIS were not intended to dis;111(1wthe possibilily that others may ultimately be implemented. It is meant only to develop the iymtml r;inp’ of potential reuse options available. . 7-9 I also believe there continues to be a need to evaluate the use of the facility by private corporations ,id Kovernnient contractors for the same or similar work performed by the Department of the Army. If ]I1(; is to close, Hoosiers are deserving of a better departure by the Department of the Army.

8 HONORABLE LEE H. HAMILTON, STATEMENT BEFORE THE PUBLIC HEARING IN MADISON, JUNE 24,1991

Congressman Hamilton’s Statement read at the public hearing duplicates his comments addressed under comment 1-1, Honorable Lee H. Hamilton, letter of May 21,1991.

9 HOOSIER ENVIRONMENTAL COUNCIL, POLICY RESOLUTION ON THE JPG READ AT 1’UBLIC HEARING IN MADISON, JUNE 24,1991

9-1 The chemical and solid waste contamination at Jefferson Proving Ground should be cleaned up to thc extent that all present or future threats to surface water, groundwater, and air quality are reduced through surface cleanup to maintain the goals of paragraph #4 (statement that JPG is home to many . spcuric~sand represents a potential major contribution to the need for large tracts of continuous forest). I’riority should be given to all landfill sites and uranium oxide contamination sites, which should be clrmcd up to meet the standards of CERCLA.

RESI’ONSE See response to comments 1-1 and 1-2. In addition, the ultimate reuse of JPG property has yet to be determined.

9-2 The JPG site shall be maintained intact as one property, managed by a federal, state, or private agency with natural resource experience;

KESI’ONSE: The Army must and will evaluate and consider all reasonable reuse options in * sii liscqiieiit environmental documentation.

9-3 ‘I IN’US. Ilcpirtment of Defense maintains full liability for all cleanup costs and environmental ilciiii6i~;c~s,si~iJ the DOD retains permanent responsibility for security, safety and environmental iiioiiitoriiig, whatever the final disposition of the property; l

KLSI'ONSE: The Army will allow for the continued timbering activities within the installation. The ultimate reuse of the property has yet to be determined. See response to comment 4-13.

9-5 The DOD shall provide for the ongoing and pernianent practice of eliminating or minimizing the short and long term risk of environmental contamination from ordnance testing activities, and recover promptly all ordnance.

RESPONSE See response to comment 1-1

10 WILLIAM H. SAGE, LETTER OF JUNE 24,1991

10-1 For the following reasons the closing of the Jefferson Proving Ground would be a mistake, an error in Judgement, an unbelievable miscalculation and an unheard brand of reasoning. (Letter lists 9 reasons)

11 AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES LOCAL 2797, STATEMENT KEAD AT PUBLIC HEARING IN MADISON, JUNE 24,1991

11-1 It (EIS) fails to address the problems of 55,264 acres of contaminated ground; the contamination being twenty three million (23,000,000) unexploded rounds of ordnance. The study fails to address the problem of cleanup of any munitions in the entire report.

KLSI'ONSE See response to comment 1-1.

11-2 11 (IilS) tries to deal with the approximately 3,000 acres in the south end of the Proving Ground, hit hiis to t.\ke into account that numerous "dumps" and test areas are or have been located there.

11-3 11 (I;IS) fails to address the facts of costs. It does not address the idea of what if no move is made

,III~cvcrything stays the same. This should have been used as a benchmark in the report. How much money would be saved if no move was made: How many acres of land would not 1)~contaminated? How many animals, plants, and ancient sites in an ecologically fragile environment would not be disturbed by not moving the mission to Yuma Proving Ground and closing Jefferson I’rovtng Ground.

KESI’ONSE: Cost savings indicated in the Commission’s report have been audited by the General Accounting Office. The ElS process is modified by the Base Closure and Realignment Act. Specifically, it states that the EIS does not have to consider the need for closing or realigning an installation. The no action alternative in this case, as discussed in Section 1.2, is the benchmark against which the proposed action of closure is compared and evaluated. The decision to close and realign JI’C was made and enacted as law as a result of the Defense Secretary’s Commission on Base I

11-4 The laws and regulations state that the land has to becleaned (cleared of hazardous waste) before any sale of the land.

IUSPONSE: A statement of condition will be prepared based upon a RI/B investigation before the disposal of any property.

12 JPG SURVIVAL COMMITTEE, STATEMENT READ AT PUBLIC HEARING IN MADISON, JUNE 24,1991

12-1 In the Public Scoping Meeting on June 8, 1989, the major area of public concern related to the amount of explosive and unexploded ordnance and its cleanup, other hazardous materials and wastes, the potential for reuse, and some concern for the wildlife. Apparently the unexploded ordnance and dcplcted uranium are of no major concern to the government. Ninety-five percent of the land is contaminated by unexploded ordnance, yet only a page and a half of the Draft Environmental Impact Slatenicnts devoted to this issue.

KESPONSE: The Army recognizes the seriousness of the UXO and DU concerns at JPG. Additional research required to address the UXO problem will be covered in separate and subsequent enviroiimental analyses and documentation. A decommissioning plan will be submitted to NRC whicli specifies how DU contamination will be cleaned up and to what extent. See also Section 1.3.4.6.

12-2 I rdly expected to see pliotographs of the types of munitions laying out on the impact fields. 1 cxpc-i-tcd niaps of Jl’G showing the impact fields and a listing of every type of munitions tested on JPG since 1941 KESI'ONSE: See response to comment 7-4. Figure 1.3.4-8 depicts the approximate location of impact lickis.

12-3 'I'licre is not even n discussion about clearing the unexploded ordnance from the south end which is 11ot clear of unexploded ordnance contamination.

12-4 I expected a document that would illustrate to the residents of Arizona what an environmental nightmare that they can expect in the future. How can they plan for a reuse of Yuma Proving Ground when it is no longer needed by the Army?

KESI'ONSE There currently are no plans for the closure or reuse of YPG.

12-5 What we received here is a perfunctory, fill in the blanks document that does not satisfy the legal rcquircmcnt of the base closure law and in no way helps society now or in the future.

KESPONSE: The Army has determined that the document is legally sufficient, in compliance with NEPA and adequate to take the proposed action.

12-6 (Mr. Moores letter provides a lengthy cost analysis.)

12-7 I low is the Army going to reconcile the fact that Public Law 100-526 gave the Secretary of Ikfeiisc the authority to sell the land of a base that is closed yet comply with DOD Standard 6055.9 which states that the land must be rendered safe prior to sale to the public?

RESPONSE: See response to comments 1-1,1-2 and 4-21

12-8 I low docs the term "long-term caretaker status'' comply with the base closure law? Under a IkL-iiw froin tlic Nuclear Regulatory Commission, JPG test fires depleted uranium rounds. The .igrccniciil is that wlicn testing stops the Army must immediately cleanup 1,200 acres at a predicted (',,st of $14 niillioll. t low is this "caretaker status" going to coinply with this signed agreement with the rd IK'?

RESI'ONSE: 'l'lic Ihse Closure and Realignment Act requires that the Dcpartment of the Army coiihidc,r tlic environmental consequences of the proposed closure of JPC and realignment actions to YIY;. This LIS complies with NEPA in accordance with the Base Closure and Realignment Act. The ~*st;ihlislimentof a caretaker status does not preclude the compliance of the base closure law. The Army will comply with its requirements to prepare a decommissioning plan to the NRC as required uii(1c.r its current NRC license. See also comment 12-1.

12-9 l’he Madison Courier carried an article on Saturday, June 22,1991 which is included as Exhibit 1 11~1ed:“Iiiivironmental Laws Hamper Base Sales”. The crux of this article is that public law states that ;in entire base must be cleaned up before any pnrcel of it is sold. How can the Army pick and choose certnin areas to study for cleanup under the National Environmental Policy (NEPA) of 1969. Bases c.iniiot be closed until an Environmental Impact Statement is completed! The entire base must be uinsidcred. The Army can’t pick and choose sites within the base to cleanup. We feel that this subverts the spirit of the law.

KESI’ONSE: The article referred to Pease AFB which is on the National Priority List (NPL). JPC is not $111 NI’I. site. The law does not apply. See response to comment 1-1. The parceling of JPC is not a clos~treissue, but will be discussed in subsequent NEPA analyses and documentation dealing with clcuiiup and reuse decisions.

12-10 The Yuma newspaper has an article in it stating that the Mayor is urging residents of Yuma to cnnserve water. What is the effect of moving 200 more families to an area that is already strapped for water?

13 INDIANA DEPARTMENT OF NATURAL RESOURCES, DIVISION OF OUTDOOR RI~CI

I.’%- I ‘1hc Jc*ffcwonI’roving Ground contains a rich diversity of fish, wildlife, botanical, and other II~III~IJIrcsoiircrs. Under current management practices, these resources have been available to the 1~~11ik.ofIndiana, subject Lo Army restrictions. Regardless of any decision to retain or close JPC, our sil:c’nc y Ixslicves that thew resources and the recreational benefits they provide should remain .iv~iiI~~l~k~lo tlic public.

ltI:Sl’ONSE: ‘[‘lie Arniy pl,ins to continue the limited recreational opporlunities currently. available to 1111. [)UbIl< 13-2 If the final decision regarding closure involves deactivation of military management anc ~)Ic~s~YI~w,consideration should be given for public ownership of all or part of JPG. We would n*

I lit, propc,rty's natural resources.

KESI'ONSE: I'ublic ownership and the associated consumptive/nonconsumptive uses will be Lxinsidered in future reuse alternatives. These future reuse alternatives will be addressed in future ~wvironmentalanalyses.

14 JOHN O'NEIL, JUNE 12,1991 (Comments are paraphrased from a marked-up copy of the EIS.)

14-1 Additional reuse alternatives include linear accelerator, above-ground nuclear waste storage, waste separator center/compactor, and experimental munitions.

11-2 II'rescribed] burning improves on nature.

14-3 Turn over the controlled deer hunts to the Fish and Wildlife Service

I< I!S I*()NSII: Comment noted

11-4 I hirinl; the caretaker status, turn over the annual timber harvest to the Forest Service

14-5 [Acicl tlw letid contaminated1 water wells in Madison to the JPG regulatory oblipltions KESI’ONSE: There is no evidence of lead contamination of wells in Madison due to the offsite ini~rntionof contaminants from JPC.

KESI’ONSE JPC has always complied with its NRC license and its allied Environmental Radiological Monitoring Program. According to the DU monitoring results no uranium has been detected in stdace or ground waters. Monitoring is required under the NRC license to verify that no radioactive m,iterials migrate off-site. Monitoring is performed every six months. Animal tissue is monitored 011cc n yex lor radioactive materials in conjunction with the annual deer hunts.

14-7 ’l‘here is a one foot error in survey at the emergency spillway of Old Timbers Lake. Flood c~rnditionscould make downstream areas hazardous.

14-8 A lot of suspended solids were from the water wells (lime stone). How about cyanide NPDES pcrmit violations at the sewage treatment facility.

14-9 ‘ilie total prehunt deer population of 3,500 to 5,500 is way low.

KESI’ONSE: The deer population estimate was recently provided by the JPG Natural Resource M,in:ip*r.

14-10 Airording to the NRC application, there was no environmental impact (DU)and the uranium W,I\ iiii~>-r~i~ii(iactive.

1~13I’ONSl~:JI’G submilted an EIS for the DU testing license. JI‘G identified DU as a low level I ,1<1 iosi(.tivcsource.

li ,\II

15~I L~~NIII rcvii’w ol the l>l

16 MIKE MOORE, LETTER OF JUNE26,1991

C‘oinineiits A, 8,C and Dare addressed in Comment 12 of the Public Hearing comments.

16-1 The meeting to receive comment on the DEIS brought a surprise. We did not expect the Corps to st.itc that this EIS would only cover the period from now to closure. Then another EIS would be performed after the base was closed. Is there any other base, landfill or cleanup site that has been clcancd up with two EIS’s? Can you explain how the decision to conduct the two EIS’s was arrived at and who made the decision?

KESL’ONSE: Inasmuch as the decision to close and reuse are distinct, the Army now generally xpir.ites the closure, clean upand reuse issues into separate environmental analysis.

As the lilS developed, it became obvious that cleanup and reuse could not fully be addressed within the time period allowed to prepare the EIS. The EIS must be finalized and the Record of l~t~~-lSl(Jllmust be signed by the end of September 1991, as required by the Base Closure Law. The cle.iiiup and future reuse of JPC or other disposition of the property will require additional NEPA 6iiialysisand docunientation.

17 JAMES A. BI

17-1 Ab .I t.ixp.iyer, resident of Jefferson County, Indiana and chemical engineer I think it a serious ni‘il1t.r 111.11 tlic, Ammy consider lull cleanup of the JPC site.

I< I:SI’ONSL:: The Army is committed to nwetiiig installation requirements concerning environmental tcy,iil,ilciiy c~imipliiince.‘Ilie Army is required by law to cleanup all areas posing a signilicant risk to

I~II~II.III Iii~,ilt/ior tlic iwvironmc~nt. 18 MADISON INDUSTRIAL DEVELOPMENT CORP, LETTER OF JULY 1,1991

18-1 I Ihink lhc lack of knowledge about existing contamination is a major omission in assessing the ~,iivir~iiiiii~,iitalaffccts of the closure of JPC. Because we do not know how contaminated JPC is, we c~,iiin~ithnow if cessation of testing ordnance will result in the cessation of additional environmental ~.(iiit~iiiiiii.iti(iii.We also cannot know what types of remediation are required, we cannot know if irc~niLdialieinwould have a more adverse affect on the environment than continuing to operate JPC as an ordnance tcsting facility. This does not even consider a comparison between the anticipated cost sivings and the actual expenditures which may result.

18-2 11) suninintion, the lack of complete and accurate information for the DEE only compounds the problcm caused by the same lack of information on which the Base Realignment and Closure C~iiiiiniis\ionbased its decision.

I(I3 1’0 NS E: Comnien t noted.

I‘J I,NVII(ONMENTAL SYSTEMS AND SERVICES, INC, LETTER OF JULY 8,1991

t(J-1 I WAK urprised to find that no investigation of the range environmental status was planned by th. AIII~Y. The l

I(I.SI’ONS1~::Sc*e rc’sponsc to comment 1-5. I

I‘J-3 Ihring the meeting it was stated that the DElS was to only address the issues regarding closure aiid aiiother EIS will address the issues regarding post closure. If this is the reason why a RI/FS is not rcqiiirid lor the range then it can be extrapolated that the RI/FS for the 3,000 acres is unnecessary at this tiiiw too, and if true then the Army should wait for the post closure EIS for implementation of any KI/FS wcirk. Clearly an investigation needs to be perfornied for all of JPC,as part of the closure xtiiiii.

KESI’ONSE: See response tocomments 1-1, 1-2 and 1-5.

1+4 In listcning to the comments presented at the public meeting, I believe that what will satisfy public concerns is a draft plan performing a Preliminary Assessment/Site Investigation for the range.

KESI’ONSE: See response to comment 18-1

19-5 I bdicve that even if the Army retains JPG in caretaker status, an investigation into the extent of r:iiii;c contmiination and potential health, safety and environmental risks should be conducted as is plmii~dfor the 3,000 acre area as identified in the draft EIS. The first step is to identify the extent and qii;intity of contamination at JPC. What will be done about any contamination that is found must be cv.ilu;itcd based upon the risk assessments developed as part of the Army‘s restoration plan at JI‘G.

20 I IONOI

20-1 As indicated in my testimony on the DEE at the June 24, 1991 public meeting held at Madison I lil;li School, I believe several of these photographs should be included in the final EIS in order to alert IIK.piil)lic. tu the very real risks associated with this site.

KESI’ONSE: Scc response to comment 7-4

?I I)AI

ItESI’ONSE Cessition of the testing mission is expected to have a beneficial impact to wildlife due to clcvrc~.,isedlcvel of disturbance, regulated public access and the cessation of noise. Adverse impacts to scvcral wildlife species due to closure, would occur from the cessation of prescribed burning. While it is true that several endangered species surveys have been recently funded and are being initiated, c-urrtwt knowledge regarding wildlife resources is hampered by the nature of the mission. Wildlife information provided in the EIS is based on available data, expert opinion and limited surveys. See rrsponsc to comment 4-13.

21-2 ’l’lic.report states that there is a good possibility that the four-toed salamander and northern red s.il;iin;inder occur on the property. Based on published distribution map information this is true. I lowever the microhabitat requirements of these species are such that it is extremely unlikely that they will he found at JPG.

21-3 The EIS is a superficial and inadequate document because an adequate survey of the botanical and zoological resources at JPC has never been conducted. I do not see how sound environmental judgements regarding future activities at JPG can be made on this document. The EIS is simply a sl.itement of ignorance.

It1 SI’ONSE: The natural resources sections are all sufficient to adequately inform both the Army and tlic public of environmental factors bearing on the alternatives under consideration. See also response ICI i riniincmt I I

22 I)lil’AICIMENT 01: HEALTH &HUMAN SERVICES, LETTER OF JUNE 28,1991

22-1 It is stated that surface waters niay be affected by the contribution of existing pollutants from 5t11kwhich nlrcady have been contaminated. Groundwater contamination to off site users is also po~~ililcwith the closcst potential snurce being Gate 19 Landfill. As noted, the past usage and III~.INIS:II of 1i;iz;irdous niatcrials niay have a long term impact in which the level and extent is ut11 I rmtly unknown. ‘lhcreforc, mitipition plans for minimizing these potential impacts should

111, Iiidc, ;iinc~iigother identified measures, the erosion and sedimentation plan indicated as needed in tlu, I l.:lS, ,ind c.~intinu;itionof the monitoring plan to detect possible migration of contaminants in the

1111 1 I1I~ . KESI'ONSE: See response to comment 1-3. In addition, formulation and implementation of a s~~linietitand erosion control plan will occur at all areas having significant risk of contamination, and at tliosc areas where soils are susceptible to erosion. The above mentioned investigations also will iclcmtify thc possible migration of contaminants. All areas having a significant risk will be remediated iii sic~t.ord;inwwith npplic.1 blc 1;) w.

22-2 Scvcr'il corrections are needed in the list of addresses receiving copies of the DElS for future rL.fcrcncc3. The Department of I Iealth, Education and Welfare, listed in two National addresses and OIW rcgional address, has been renamed the Department of Health and Human Services for a number of ye.irs. Mr. Charles Custard should be deleted, and the address for the Centers for Disease Control should be revised to reflect the address on this letter.

ICESI'ONSE: The text has been revised to reflect this change.

22-3 I'lcasc insure that we are included on your mailing list to receive a copy of the Final EIS, and future EIS's which may indicate potential public health impact and are developed under NEPA.

ItESI'ONSE: Your organization is included on the FEIS distribution list and will be included on all future lists relating to public health.

23 AICTtIUII B. ALPHIN, LETTER OF JULY2,1991

23-1 I'lw UXO will not release contaminants into the groundwater supply. Further, it will not release c lotici~of h.i/ardous gases. Even if a forest fire were to sweep the area there would be no danger ~irit\idcthe boundaries of Jefferson Proving Grounds.

I(1SI'ONSE: Comment noted

23-2 It is unfortunate that the decision has been made to close Jefferson Proving Ground. I disagree will1 ~Ii~it.I Iowcver, if the closure must be done, then 1 fully support fencing off Jefferson Proving (;r~iiiiidiind Ictting it lie fallow. The contamination is benign. From the economic standpoint and the Iiihtoric and fiiture value standpoint, it is best not to disturb it but to let it lie fallow.

24 I(VAN BAYH, COVEKNOIC, STATE 01: INDIANA, LETTER OF JULY5,1941.

?+I I (Io iwt Iltd io reitcrate a11 of the concerns expressed by IDEM, but 1 want to be ciear that the I)CYII)I,, 01 IIiciiLiii;i will not toli~r'itcthe evcr increasing environmental dangers and the real public s..~lk,ty risk5 tl~it;ib;indonnicnt of JPC wilhout adequate cleanup represents. KESI'ONSE: See response to comments 1-1 through 1-5.

25 INDIANA DEI'AIITMENT OF ENVIRONMENTAL MANAGEMENT, LETTER OF JULY 9, 1'"

25-1 'I'Iic Ills proposal to place the area north of the firing line in caretaker status is also contradictory to thc coinmitinent in tlie EIS that the DOD intends to close the facility in accordance with RCRA rcy,iil;ttions. 'l'he UOI) dcyision to proceed with closure for a few of the RCRA regulated solid waste m;in;i~;cinentunits in the area south of the cantonment area ignores the very serious problems north of the firing line. The failure to address the units identified in the March 1990 Enhanced Preliminary Ih-port violates Fcderal and State closure laws under RCRA and State Solid Waste Rules. Simply providing security for the widespread contamination that exists north of the firing line does not constitute proper or legal closure of the waste management units on the facility and does not therefore support tlie contention made in the EIS.

25-2 Of nicijor concern to this agency is the lack of plans to address unexploded ordnance downrange frum the cantonment area. The EIS states that UXO can be found virtually everywhere on JPG. Given this iidniission and the death and injury experienced at other facilities, there is no reason to believe .iny s(,rious consideration has been given to public safety.

25-3 'l'lwrc is also no indication of consideration being given to the potential affects of l~i~i.i~,~.~iiii~il.iti~)iiin game species resulting from contact with hazardous constituents from UXO.

25-4 'l'hc IiIS docs mention plans to conduct a natural resource inventory and appears to recognize the vahc of tlw natural resources at JPG. However, plans for the protection of those resources area wocfully in.~Jcquate. Of parlicular importance is the presence of a great blue heron rookery on the hrility. 'l'hc lilS fails to discuss any plans for the protection of this valuable resource.

KESI'ONSE: The cessition of the testing mission at JPG is predicted to have a beneficial impact.to iiatural resources, including the great blue heron rookery, due to a decreased level of disturbance. I'iiblir access will continue to be strictly regulated and controlled thus protecting sensitive resources li~idhnbitiits. Protection and isolation of sensitive wildlife habitats will continue after closure. Thus, prok>ctionof natural resources at JPG is not a significant closure issue. Funding has been approved for ;in endangered plant survey conducted by the Indiana State Nature Preserves, Division of IDNR. A siirvey will be conducted this winter. Also, an initial field survey for the bobcat was conducted. A survey for the Indiana bat is in early planning stages. As long as the property remains under Army jurisdiction it will be managed in accordance with DOD and Army policy of sustained yield and multiple use management where possible. See response to comment 4-13.

25-5 A RI/B must be undertaken to study all six streams to determine the extent of contamination and walualc the risks to human health and the environment on and off the facility.

KESI'ONSE: See response to comment 1-3

25-6 While the stated intent of the EIS is to evaluate the environmental impacts of base closure, it is a f.ir rtwhing assumption that the curtailment of activities at JPG will have no negative impacts on wildlife. The 1% lacks sufficient data and detail to adequately evaluate any impacts, positive or iiq;iiIive, and certainly lacks commitment to fully address this vital concern.

KIISI'ONSE: As stated in response 25-4, cessation of the testing mission is expected to have a lwn~~Ii~~i,ilimpart to wildlife due to decreased level of disturbance, regulated public access, and the ct~ii~i~~iiof noise. Adverse impacts, to several wildlife species due to closure, would occur from the <.t.ssitioii of prc*scribedburning. While it is true that several endangered species surveys have been r(u.iiIIy fiiii

Iiy 111~.ii.iliitt' 01 thcs niissicin Wildlife inforniiitioii provided in the EIS is based on availahle data, t'\lx,i I o1)iiiioii li~idliniittd siirvcys.

25-7 11 ih OIII o1)iiiion thiil thca Ills falls far short of ;idcipitely assessing the environnientnl impact of

Ii~i~t~~INIIC, M;iiiy of II)IiM's commeiits and concwis expressed previously were either coniplrtely ij;iioi.,,,l or iiicmtioncd unly in general terms. There remains a complete lack of pertinent site data WIIKIi 'ire c5sentiaI to fully evaluate the impact of base closure and to develop viable future plans for tilc rclclilty

KESI'ONSE: Many issues expressed during the scoping process are beyond the action contemplated

111 thih lIlS .ind will bc idcntified in future environmental analyses dealing with reuse and cleanup. See .iIso rt.sponse to comment 25-1.

25-8 'l'lic 1X)D indicates in the EIS that it has no plans to collect the data necessary to truly evaluate tl~cwtcnt of contamination or to remediate the most significantly contaminated portions of the IAC ilily. Indeed, projected closure action for the units north of the firing line indicates otherwise.

KESI'ONSE: This EIS does not address specific actions or impacts associated with cleanup, nor was I(\ StdtLKi purpose to achieve this goal. Hazardous materials are discussed to the extent that they affect or .iri' 'iffected by closure or realignment. By law, all areas having a significant risk must be rt-mcdi,ited. See also Section 2.2.4in the EIS.

25-9 'l'licIDLM believes this EIS is inadequate and incomplete and proposes totally unacceptable base clcisurc- conditions. This statement is based upon the failure of the DOD to fully evaluate the cmvironniental impact of base closure (l),the lack of commitment to conduct a comprehensive facility reineiiicil investigation (2), the failure of the DOD to evaluate or to consider the cleanup of the most Iiih;lily contaminated portions of the facility (3), the lack of a realistic or thoughtful discussion of future Liduse options (4), and the unresponsiveness to previously provided IDEM concerm (5).

KESI'ONSE: Responses to your summary comments are provided in comments 25-1 through 25-8.

26 l>ll

'26-1 I ht4ic-vc that the EIS should evaluate in detail the long term environment risk froni uncxplodcd orciiicincv in the base's range area. Ordnance is composed of toxic substances, including white lilicispliiirus, IWX, 'I'NI', etc. In fact, several Army ammunition plants are on the Superfund National l'riiiritics I.isl for precisely this reason.

KI3I'ONSE: 'l'liis IilS doc's not address specific actions or impacts associated with potential i,~iiic,cli.ition ;ictivitics at JPC. Hazardous and toxic materials are discussed to the extent that they .II~~VIor c~tn*;iflectcd by closure or realignment. The Army is committed to meeting installation

I LY~Iii.('iiic.iits concerning environmental regulatory compliance. The Ammy will implcmejit a sampling

~V~I~;I.III~d ;ill streams to drtcrmine if contamination is present in concentrations that would bc Ii.iz,irdous to human health and/or the environment. All areas having a significant risk must be rt.intdi.itcd in accordance with CERCLA. Your concerns will be considered during subsequent

.in.ilyscs ;issoci;itcd with reuse and remediation activities. The Army will continue to conduct research iirto tlw toxicity, transport and fate of explosives and byproducts.

26-2 Over a period of decades, toxic chemicals from the ordnance can move off base in ground and 4iii-f.ice waters. Monitoring the water is an inadequate method of evaluating the risk of offsite cuntnmination, since the contaminants must become a serious environmental threat before anything is donc about them. You can’t put the chemicals back in the shells. l

26-3 ‘1’0 adequately protect the environment at and around JPG, it is important to do a detailed projcclion about the toxic life of the explosives via their byproducts, to make an assessment of the likelihood that the chemical will spread from their shells, and to develop models of environmental dispcrsion.

26-4 The risk of toxic contamination from unexploded ordnance is not unique to Jefferson Proving (;round, but this facility represents one of the most severe cases. If in the course the type of study that I propose, it turns out that other, active proving grounds pose a similar environmental risk, then the Ariiiy should develop procedures to mitigate the risk at those facilities as well.

ItESI’ONSE: See response to comment 26-1. The EIS concerns the discontinuation of the mission at JI’G, the withdrawal from and the closure of JPG and the realignment of the test and evaluation mission to Yuma Proving Ground. The environmental analyses undertaken within this document are yic-cific to the implementation of the Base Closures Commission’s recommendations of transferring tlw <.urrc.iitniission at ]IC to YTC and the process of closing JPG.

20-S l’tdiiips the greatest long term threat of toxic exposure at JPG is from the ordnance in the impact

.)I c..i\~ It wotild make ii mockery of the environmental review process to ignore that thrtvt merely lwc,itix~tlic Army currently has no plans lo restore the massive piece of real estate.

Iirdiiip, regulatory complicuice. Although the Army has not explicitly noted the intent tu cleanup

~,,iit.iiiiili~it[,(iareas, we are required to cleanup all areas posing a significant risk to human Iieallh or IIN. c.iivirtrniiient. All areas having significant risk must be cleaned up in accordance with CERCLA. 27 MR. SIERI'S, SUMMARIZED FROM AUDIO TAPE, JULY IO, 1991

27-1 Area is too contaminated with UXO to clean up and therefore unusable for purposes other than il.; ctirrc'nt purpose.

I(ESI'0NSE: Since the level and extent of UXO contamination is currently unknown and could be foulid virtually anywhere on the installation, future use cannot be determined. Under the Base Closure Act, JPC is rcquircd to close and the currenimission at JPG is required to cease. General reuse o1)tioiis arc' identified and further analyses will be provided in subsequent NEPA analysis and ~l~)ciimi~ntation.

27-2 Security, during caretaker status, will be lax. Unauthorized entry for poaching and other reasons will increase, thus placing more people at risk from injury by exploding ordinance.

IIESI'ONSE: The perimeter fence will be secured and maintained to prevent public access and off- post land use encroachment, preserve public health and safety, and protect government property from illegal cntry and vandalism. Public safety service areas for security and fire protection will also be requ i red

27-3 Closing JPC and realigning to JPG doesn't make economic sense

KESI'ONSE: See response to comment 2-6. This EIS does not address the financial data nor estimated cost savings that were considered by the Base Closure Commission during the closure and rcali~nmcntdecision making process.

28 ENVIRONMENTAL PROTECTION AGENCY, REGIONS 5 AND 9, LETTER OF JULY 15, 1991.

28-1 l'tie upcoming Remedial Investigation Feasibility Study (RI/FS) for the cantonment area and "s.inipling program for selected sites and streams" should be scoped to obtain contaminant data in downrange and cantonment areas as required by the Screening Site Inspection (SSI). We also rcwiiiiiiuid that information and protocols required during the RCRA permitting process be t,oiisilk*rid 'I'he Army should include the sampling reconimendcd in its Enhanced Preliminary A+v,>s!iiciit (A[ywiidis J of tlw I>1:IS north of the fireline and should indicale in the Record of Decision (I<()I )) tli.rl it will procLvd with the Installntion Kestorntiotr I'rograni for the entire installation. In our w)iiiiit; colmi(*iits, we rcquesteci that existing impacts to surface and groundwater from exploded and ii11~~~~11~1cl~dotdnnlice hr cv.iliratcd and assessed. Monitoring needed to assess these impacts has not INY~Ii~~rforiiird to datc. Jcffcrwii Proving Ground has been required to perform a SSI under Section 120 I,( ('1ilK~I.A wliic.1) must be siibinilted to US. EPA in Septeniber, 1991 so it can be scored for iio,.xlilt, iii(.liisioii OII !lit. N;ition;il Priority List. 'fhc above sampling must be performed as part of thc SI( ;nniiidwatcr inwiitoring is required at waste explosive, open burning and open detonation areas by IK'KA regulaticms. Therefore groundwater monitoring will be required both south and north of tlit, firing linc. Also, solid waste management units (SWMUs) may be required to have groundwater nioniturcd

'l'hc Army has submitted an enhanced preliminary assessment (PA) report (March 1990) and ni.istcr cnvironmental plan (MEI') (November 1990). In addition, the Army is scheduling an RI/FS for LIK,Jl'(;'s c.antonment area and site-specific sampling and analysis (S/A) for the North area. The l

'I'tic*site-bpecific sampling and analysis will include surface and sediment samples from all the iurf.iw strc*ams that traverse JPG. Groundwater samples also will be collected from groundwater ni~initoringwclls that exist at an impact field (interior of JPG's North area). These samples will be ~iii,iIy~~dfor UXO chemical constituents (including heavy metal5), pesticides and uranium isotopes.

'1'1~' l

I i>h to l~iiin;i11Ilc;illh and the environment is significant.

28-2 I,:I'A is wncerned with the potential for significant adverse impacts to terrestrial and aquatic <~~~\y>t~~irrsincluding streamt;, wetlands and ponds, wildlife including threatened and endangered

~ICYI~~S,<.i.iti<.,il li:il)itclt and to water quality that could result from surface and subsurface clearancc opctcitioiisat JI'G. Therefore, the FElS should include a full range of cleanup alternatives necessary for

It.vc'lr. (if IWISC and aiiticipatcd reuse at JI'G and the environmental impacts associated with each t I~~;II~~I~I,illt,rniilivc-. 'l'liis analysis of ~~lti~rn~~tivc~sshould assess impacts to vegetation, wildlife, tlircaittmdand endangered species, critical habitat, wetlands, riparian corridors, and to surface water, ~;rounJw.iterctc. These impacts should be compared. Such a comparison would allow an informed &-cision on general cleanup alternatives at JPG to allow anticipated uses at JPG and realignment tilkcwiiikive at YI'G. The FEIS should outline a mitigative action that will be implemented to offset ;idvcrsc unavoidable environmental impacts. Separate NEPA documentation should be prepared for edi remediation and land reuse before implementation as indicated in the DEIS. This should also be rcsflected in the ROD. The FElS should include alternatives which protect and enhance rare undisturbed natural communities and the wide range of existing upland and aquatic habitats and wildlife and fish populations at JPG.

IIESI'ONSE: This ElS focuses on the mission-transfer aspects of the BRAC action rather than specific actions or impacts associated with potential cleanup activities. Cleanup of JPC is independent of closurc'. I lazardous materials are discussed to the extent that they affect or are affected by closure or rc~~~li~~nn~ent.'I'he Army is committed to meeting its responsibilities regarding fish, wildlife and n~ituri~lresources pursuant to all applicable laws and regulations. It would encourage others to do the sinic. upon transfer of such lands. All cleanup impacts, future reuse alternatives, reuse associated impacts and any required mitigative actions will be addressed in future NEPA analyses and docu menta t ion.

28-3 One of our main concerns, which should be addressed in FEE, is the potential for contamination of downrange areas at YPG with UXO. The FElS should describe measures that will be taken to prwc'nt thc accumulation of UXO.

KCSI'ONSE: The proposed impact areas for the realigned mission (PAT) will be located in areas that arc* currently bcing used for similar activities. Measures to be taken to minimize contamination and xcuniulntion will be accomplished by following requirements of Army Regulation 385-100 and ;ic(liiisitioti of appropriate resources to cleanup UXO. AMCR 385-100 requires that the Army niiiiiiiiiy.c, klie lruard associated with munitions-related activities whenever possible. The lack of ,IC,IIW. vc.>;cLiti

23-4 1'1~'1)1:15 siimm;iry refers to studies that hve not been completed and mitigation measures wlikli "will (IC cit*vclopcd." In sonic instances tlicsc involve impacts which would result from the pio1)ohtxl ri*;ili~;nmc'nt,aiid which could bc adverse in nature. We recommend that all necessary slii(lIt.5 bc. completed and niitignlion measures developed and presented in the FEE to ensure adverse iiiii).I& ate niiniinizcd to the fullest extent possible. KESI’ONSE: Several key studies have been completed including a noise analysis and a draft cultural in’soiirccs inventory. Several other studies such as site specific vegetation and wildlife studies are underway. Current mitigation has centered around the siting of facilities within previously disturbed arcas. Additional mitigation measures will be developed when necessary to mitigate any additional Identified impacts after completion of the surveys. Mitigation measures will be coordinated with appropriate agencies.

2X-5 ‘fhe potential for migration of contaminants from UXO to surface and groundwater at JPC must I)C assessed.

KESI’ONSE: See response to comment 28-1.

28-6 Ik~scdon our review, we have rated the project EO-2. The EO indicates we have environmental objections regarding the project. The review has identified significant environmental impacts that stiould be avoided in order to adequately protect the environment. These include the contamination of apparently uncontaminated areas of the Kofa Range in a sub-altemative to the preferred alternative, and significant adverse impacts to vegetation, wildlife, threatened and endangered species, critical habitat, wetlands and water quality from proposed timber operations. The 2 indicates EPA does not believe that the DES contains sufficient information for EPA to fully assess environmental impact: Lli:it sliould be avoidtd in order to fully protect the environment. The 2 rating relates to the lack of hscline infornution on the levels of contamination of soils, sediment, surface and groundwater. Data must be provided to the extent available on Contamination in and downgradient of areas containing UXO from explosive residues and leakage of explosive compounds, metals etc., from UXO and use of hcrbiridcs and pesticides. The potential for migration of contaminants through all media and It*rrcstri;il and aquatic biotic resource must also be assessed. Sufficient information on the above factors must be obtained to indicate whether or not human health or the environment is endangered as a rcwlt of migration of contaminants and/or exposure of receptors to these contaminants. The proccw that will be followed to obtain this information as the Installation Restoration Program (IRP) work continues at JK,must be fully described. Additional information on the biotic resource of both JIY; and YI’C is also necessary to assess impacts of closure, and increased timber harvesting during c;irc*takrrsliilus at JPG and of realignment at YPG. The FEIS must also identify all anticipated land it’iihc cIc;ir.incc that is necessary for each. The environmental impacts of any range clearance which nuy lic nc*cdcci to prevent exposure of receptors to contaminants and/or containment migration lind/or to ;illow for idrntified land reuse alternatives must be assessed and identified.

It IISI’ONSE: This tils addresses the environmental impacts associated only with the prc+ioscd actions tu 1,ltisc JIY; mid rciiiign llie munilion testing mission to YI’C, as mandated by the base closure slntutc I~~LIIIOW-OIINlil’A analysis and documentation will address the future reuse environinental impacts, once viable alternatives have been identified. The rating of EO-2 and the general presentation of most of the EPA comments suggest a misunderstanding that reuse and cleanup evaluations are the intent of this EIS. The issues raised and concerns expressed by the EPA are valid and will appropriately be addressed in follow-on NEPA analysis and documentation. The Army has made every reasonable effort to ensure that this EIS analysis and documentation is complete, accurate and legally sufficient to appraise the public and decision-maker of the environmental impacts of the proposed action.

The cessation of the testing mission at JPG will have a beneficial impact to natural resources due ton dweased level of disturbance. Public access, after closure, will continue to be strictly regulated and controlled, thus protecting sensitive resources and habitats. As long as JPG remains under Army cmitrol, it will be managed in accordance with DOD and Army policy of sustained yield and multiple use management. The Arniy will prepare a Natural Resources Management Plan that will address tlirentcned and endangered species, species of concern, wetlands and other resources at JPG. This plan will comply with 32 CFR 265 and all other applicable laws. A sedimentation and erosion control plan will also be prepared and implemented.

28-7 The FEIS must define the preferred realignment alternative at YPG. Alternatives within the alternative that involve areas of the Kofa Range which are not currently contaminated with UXO should either be included as part of the preferred alternative or addressed in separate NEPA documentation.

RESPONSE: All proposed realignment actions involving the preferred alternative are in portions of Kofa Firing Range, all of which is contaminated by UXO. These actions are addressed in Section 2.4.1. The Direct Fire Weapons Range (DFWR) for kinetic energy penetration testing (e.g. DU and tungsten cnrhide) will be located south of Pole Line Road which is not contaminated by UXO. However, it must be noted that penetrator testing cannot create UXO because it is non-explosive, and that it will be fired into a catchment facility to maximize recovery. Some limited high explosive (HE) testing will be ronductcd at DFWR, but due to the nature of that testing, no UXO is expected.

28-8 If the East Arm Alternative at YPG remains viable, the FEE should discuss implications of the proposed action with respect to Native American values and impacts to cultural resources. This is nlco true of impacts to wildlife in the East Arm, in which case the DES suggests such impacts would bc significant, but offers no course of action to minimize through mitigation.

1(I:SI’ONSE: The East Arm is not considered a viable alternative due both to high cost factors as well .I.< eiivironnicntal considerations including potential contamination of the relatively uncontaminated List Aim) with UXO. Biological and cultural concerns also make this alternative not viable..

28-9 If tlw preferred alternative in the FEIS is limited to previously contaminated ranges, the potential for ~dditioiialrange areas being needed in the foreseeable future to support any anticipated growth in Icstiiiy: load should be discussed in the FEIS. Additional range needs during mobilization should be discussed. Impacts of any foreseeable additional ranges should be addressed.

KESI'ONSE: I3nsed on studies by the IDA and YPG, integration of the JPC firing missions can be accomplished within the areas proposed for use in this EIS. No plans exist for any additional expnnsion.

28-10 The FEIS should discuss the impacts of performing this cleanup and cleanup of UXO which is also present in this area. The DU impact area will have to be cleaned up in accordance with a decommission plan approved by the NRC.

RESI'ONSE: The Army recognizes the seriousness of the UXO and DU concerns at JPG. Additional analysis required to address the UXO problem will be covered in separate and subsequent cnvironmcnlal analysis and documentation. A decommissioning plan will be submitted to NRC which specifies how DU contamination will be cleaned up and to what extent. See Section J.3.4.6.

28-11 'l'he area(s) where the UXO shells landed at JPG and the area that was hit with the penetrator shells necds to be completely as possible outlined and characterized if it is to be released for other use.

RESPONSE: This issue will be addressed in further reuse NEPA documentation as discussed in comments 1-1 and 1-2.

28-12 The percentage of recovery of the UXO, DU and other DU fragments should be increased beyond the 20% level as high as possible to limit the possible contamination of the environment and myinadvertent exposure of individuals in the area.

RESI'ONSE: The 20% recovery level only applies for DU. The recovery process has now increased to Ihc 25% recovery level (Section J.3.4.6 has been changed to reflect this update). According to nwnitoring results from JPG, uranium has not been detected in surface or ground waters. Monitoring 15r~qiiir~d under the NRC license to verify that no radioactive materials migrate off-site through the air, w'itcr, scdiincnts or wildlife. Monitoring of waters and sediments is conducted every six months. Aniiii.il tisue is monitored once per year in conjunction with the annual deer hunt.

28-13 '1'1ic INshells ~houldbe treated as source materials when considering the cleanup criteria.

KESI'ONSE: See response to comment 28-10. 28-14 There is a new standard that is proposed in the Safe Drinking Water Act concerning uranium. The proposed standard is 20 micrograms per liter for drinking water. This may need to be considered if any waterway potentially feeds into a water source, either surface or groundwater.

28-15 It is possible that the National Emission Standards for radon and other radionuclides found in 40 CIX part 61 subparts t3 and Q and the unstayed portion of subpart I may need to be used when the rcmcd iii I work begins.

28-16 Elcveii groundwater monitoring wells have been installed in conjunction with investigations of (lie DU area. No rationale for selecting these well site locations is presented in the USATHAMA is 'l'cchnical Report A011 of June 1989, and no hydrogeologic and groundwater flow interpretations are provided based on data derived from these wells. Several of these well locations are not adequate for monitoring because they are located too far from the DU area and are neither up-gradient nor downgradient but are divergent from the groundwater gradient presented in the general hydrogeologic d iscussiiin.

I(ESI'0NSE: Groundwater flow criteria was taken into account in determining monitoring well pl:iccment. All groundwater monitoring procedures have complied with the NRC license. These monitoring wells were installed too far from DU area to monitor background levels.

28-17 The IDEM'S "Report to the Governor United States Army JPG Evaluation" of April 1989 rcvicwcd cleanup methods likely to be used by the Army to make the land suitable for the most likely IcvL.~~of restricted use. Reuse of JPG as wildlife refuge open to limited recreational use with coiitrollcd access and security provided by the DOD was used to illustrate a realistic restricted use clciiniip .goal as a basis of estimating range clearance costs. This is believed to represent a realistic ch~anup.goal and a basis for re-estimating range clearance costs. "About 8,600 acres of designated iinpic-t fidds would require subsurface clearance. A controlled bum would be performed to remove vcy;c%ilioii, thc ground surface would be cleared, surface ordnance would be detonated in place, and IIL~C~rcmovcd wlwn necessary. The excavation would be performed to a 3-foot depth using remotely t~oiilrollcdaid armored equipment, ordnance brought to the surface would be detonated, metal lisib;iiic,iits would be collcctcd, and the site would be revegetated. Another 2,600 acres' of land that c'ii~~onil),i!+111ts "safcty fm" areas surrounding the impact fields would be subjected to a controlled I,iiini I~III~IwccIby a surface sweep to locate and detonate in place exposed ordnance. The surface ’.wvi’p would be followed by a magnetic survey to locate subsurface ordnance. The 16,500 acres down isin};<*bclieved to be minimally contaminated would be subjected to magnetic survey and visual 5wccp lor in-place detonation of surface ordnance. While there could be an increased risk of overlooking ordnance by not clearing away the vegetation, and attempt made of to present a range cImr.ince process that could render the property reasonably safe for limited recreational purposes yet would nnt result in devastation of the natural resources.

28-18 ’fhe reduction of waste disposal noted as a beneficial impact in the FEE is dependent upon how niucli cleanup will be done at the site. More wastes may actually be produced that need treatment. ‘I’Iie cntire document needs to address the production and treatment and disposal of wastes created ditrinK closure and during cleanup activities.

KESI’ONSE: The discontinuation of testing activities at JPG is considered to be beneficial because no new contamination caused by the firing of additional ordnance will occur. However, the closure will not changc the potential for existing contamination. During cleanup, more wastes may actually be produced. Hazardous waste generated during RI/FS will be disposed of according to EPA regulations. However, remediation impacts will be addressed in future NEPA analysis and documentation.

28-19 ‘The EIS needs to describe that RCRA permits will be necessary for the Open Detonation COIl/OD) areas, since they will continue to operate until the base closes in 1995, and that these units may be necessary to help treat cleanup wastes.

KCSI’ONSE: The Army will continue to fulfill its RCRA requirement regarding open burning and opcn dclonation units. See Section 1.3.4.6.

28-20 The 1% states that RCRA closure will be complied with, yet the EPA and the State have not L)U.II informcd of closure of the regulated units, or what those details will be. The FEIS necds to xklrt>ssif tlic regulated units can clean close or not. If they can not clean close, a minimum of 30 years td ~~o.;l-closuremonitoring will be required, with RCRA permitting requiring continued corrective .wlion work. Tlic FEIS needs to address the investigation and potential cleanup of Solid Waste M~III~I~~~*II~~~II~Units (SWMUs) and regulated units north of the firing lines.

It1:SI’ONSE: Sce response to coninicnt 28-1 28-21 If there is contaminated groundwater or other liquids that need treatment, the wastewater trc',itnient plant may need to remain open, instead of being shut down. This would allow the continuation of discharges to the surface water body.

28-22 In general, the Army needs to decide the land use of the site. Without it we can not determine what KRArestrictions and cleanup levels will need to be met.

28-23 Regardless of the land use, the EPA is going to work on a clarification of whether the firing r'ingcs, that will no longer be used, still fit into the exemption as a waste or not. Since the areas are closing, they can be construed as waste since they no longer will be used. Also, remedial investigations should be done for the entire site, and should encompass all media. The boundaries of the firing ranges may be considered the point of compliance in some cases. Depending on the results of investigations a progressive cleanup over some timeframe to cleanup unexploded ordnance at the site niay be required. RESPONSE: See response to comment 28-1.

28-24 The FEIS should indicate if soil or groundwater remediation have been conducted as required under 40 CFR Part 280, Subpart F for the ten Underground Storage Tanks (USTs) removed in 1988. The b'IilS should also indicate if site assessments required under subpart G have been conducted for the four inactive USTs closed in February 1991 and whether the State has been notified of these tank closurc,s as required.

28-25 I

28-26 'l'lie DElS does not adequately assess the environmental impacts of performing PAT at YPG including UXO contamination, and impacts on air quality, groundwater, noise levels, flora and fauna and cultur;il/historic resources. l

28-27 One of our main concerns, which should be addressed in the FEIS, is the potential for contamination of downrange areas at YPG with unexploded munitions. The FEIS should describe mcvsures that will be taken to prevent the accumulation of unexploded munitions. In as much as "unexploded ordinance (UXO)contamination is widespread on the range", it would seem that cleanup would be more of a priority than indicated on p. 135, "as time and resources permit." It is acknowledged in the DEE that the introduction of additional activities will exacerbate the "coiitnn~ination"problem, therefore we recommend the Army place priority on establishing UXO cleanup plans for the range, and implement the plans as quickly as possible.

28-28 'l'hc EI'A is concerned that activities associated with the proposed realignment could increase I'M-10 cmissions in the non-attainment area beyond levels discussed in the DEE. We encourage the Army to trcat any increase of pollutant levels to an area currently in non-attainment for that pollutant as significant. Such is the case, in this instance for PM-IO. The discussion on P. 4-25 suggest that 2 Ibs/day of "particulate matter" could be expected. However, that figure reflects only vehicle p*ncratedparticulate, from commuting to and from work. There is no quantitative discussion about itnp;i~'tsfrom dust and smoke generated from actual weapons firing and projectile impacts and from iircrwscd open hurning of waste propellants. There is also no discussion of emissions that would be p,ii(,r,itid froin constriiction activities associated with the proposed realignment, or from expanded I

28-29 'lhe I:IJIS should also recognize that niajor amendments to the Clean Air Act (CAA) were cmactcd into law in 1990. The CAA amendments define "conformity" for federal projects as follows: !he fcderal projcyt must not (i) "cause or contribute to any new violation of any (federal air quality) st;ind.ird" (ii) "increase the frequency or severity of any existing violation of any (federal air quality) stand,ird" or (iii) "delay timely attainment of any (federal air quality) standard or required interim cmission reductions or other milestones." The FEE should demonstrate that the proposed realignment is fully consistent with these stringent requirements. This also involves maintaining close working relationships with state and local regulatory authorities.

KESI'ONSE: Additional discussion has been added to the air quality section on the CAA and how compliance will be accomplished. See Section Y.4.2 and response to comment 28-28.

2X-30 The Amyshould take care not to downplay the potential friability of asbestos products they've Identified ;is non-friable in the DEE. This includes asbestos tile, transite board, asbestos shingles and . siding. If these materials are left for long periods exposed to weathering, they could become friable as they deteriorate. Construction activities, including demolition and renovation of buildings with .ishestos must be accomplished in accord with guidance provided in the National Emissions Standards Cor I lazardous Air Pollutants (NESHAPS). We suggest the Army confirm its commitment to .iccoinplisli all asbestos-related activities as indicated and clarify the discussion concerning "ordinary maintcnnnce" on p.4-39.

RESI'ONSE: The Army policy is to accomplish all asbestos-related construction or renovations in conipli;ince with applicable regulations. YPG and JPG have recognized this requirement and ,iccomplish asbestos-related activities in compliance with state and Federal regulatory standards.

28-31 The PEIS indicated that a new water well would be required to accommodate additional pcrsorincl and activities at YPC. The FElS should discuss anticipated impact to groundwater and .iiiti<.ipitcd wi-11 production rate, expanding on the Army's statement on p.4-22 that "it appears (iindvi liw;idcicd) that the aquifer can safely handle the projected use." The FElS should also commit

t ooi.dinatiii); with, and obtaining permits from, appropriate state regulatory akencies.

KESI'ONSE: Current and planned facilities at the Kofa Firing Range area are not subject to high risk due to flooding. Standard erosion control measures will be implemented during construction of new facilities.

28-33 Although noted in the DEIS that YPG's RCRA permit will be modified and submitted to EPA and State of Arizona, the discussion does not indicate the anticipated timeframe for that to occur. The FEIS should discuss the need for the permit modification in more detail, and should include a section on hazardous waste minimization as well as other proposals to mitigate impacts associated with generation, storage, transportation, and disposal of hazardous wastes.

ItESI'ONSE: YPG complies with RCRA including the commitment to modify its permits to accept J I'Cs mission.

28-34 The EPA strongly encourages adoption of waste minimization programs and recycling efforts. Within this timeframe, we recommend, in conjunction with Army's discussion on page 4-35, that all incoming personnel be trained in appropriate storage of hazardous materials and waste; waste tlisposal practices; recycling, and waste minimization.

ItESI'ONSE: YPG will continue to train all appropriate incoming personnel in compliance with its 1 lazardous Waste Management Program.

28-35 Does the YPC ICUZ incorporate activities from Jefferson Proving Ground? If not, we recommend the document be notified accordingly. How will new activities affect nearby "small" omimunities? We recommend the FEE identify current noise levels and those projected as a result of tlic re;ilignmcnt alternatives.

ItESI'ONSE: A new noise study has been completed analyzing noise impacts associated with the tiCiwfcrof ]ICsmission to YE. No additional noise impacts off the installation are identified. The I,WIII\ of klic noise study are summarized in Section Y.4.3.

28-36 111 .iccord with the discussion of noise impacts to the Kofa Game Preserve on Page 4-26, we woilkl (xlx-ct kIi.11 the results of ongoing studies will be included in the FEIS along with adiscussion of Iuop,,,d mitigation nieiisurcs coordinated with personnel at the Game Preserve. KESI'ONSE: See response to comment 28-35

28-37 Ihm the discussion presented in the DEIS, it appears that additional studies need to be ac-coniplished in this area before informed discussions can be made with respect to cultural and historic resources. The DEE does suggest that cultural resources of significance do exist at YPG. We recommend that the Army continue efforts to coordinate with Native American representatives to ensure impacts to resources are eliminated or minimized to the fullest extent possible. We also recommend that coordination with the SHPO be completed and the results included as part of the FEIS.

KESI'ONSE Cultural resource surveys have been completed at all future construction areas. Register eligible sites will either be avoided or mitigation conducted in accordance with the Memorandum of Agreement between the Army and the Arizona State Historic Preservation Office.

28-38 The vegetation and wildlife surveys for the Kofa Firing Range (KFR) should be completed. Assessment of impacts are contingent upon these surveys. We recommend the results be included in the FL%, along with a detailed discussion of anticipated impacts and mitigation measures.

28-3Y Wc are concerned with the Army's statement on page 4-23 that suggests impacts to wildlife would be minimal because of "relatively low wildlife diversity." The lack of diversity in and of itself sliodd be considered significant. Increasing activities as proposed in the realignment would lead to Iiirllier environmental stress. EPA is concerned about loss of any species and/or its habitat. We cncour;il;e the Army to view this as an opportunity to work with USFWS for the purpose of dcvc.loping a spectrum of mitigating measures to minimize impacts to existing plant and wildlife iprc-icas on the range. We rccommend that the Ammy reexamine the appropriate section of the DEIS ,ind supplcwent the discussion, in the FEIS, with proposals to minimize disturbance to tlie extent 1)owililts. Avoiding targeting of washes where vegetation and wildlife is concentrated and ~-~)nt.iniiii.itionof surface water and possibly groundwater is more likely is one possible mitigation ni~*si\~irL*.We also expect that impacts to the desert tortoise would be minimized per coordination will) 0SI:WS. The FEE should reflect tlie results of that coordination. Also, the potential adverse iiii1>.i&. of nii;ht time testing of illumination devices on wildlife should be assessed in the FEIS. IIESI'ONSE: See response to comment 28-38.

28-40 The DElS summary indicates compliance with several environmental statutes is "ongoing." We arc concerned that expanding activities at Yuma could delay regulatory compliance at Yuma before adding activities that could exacerbate regulatory non-compliance.

IIESI'ONSE The Army is in compliance with environmental rules and regulations. "On going" refers to YI'G's commitment to maintain environmental compliance. YPG will assure this continued coinpliance with the transfer of the JPG mission to YPG by commitment of appropriate resources and coordination with appropriate regulatory authorities.

28-41 The "nmny environmentally unacceptable practices" that "were in the process of being rectified" ,it the time of a hazardous material survey in 1988 and steps that have been taken to correct these sliiiulti be included in the FEE.

KESPONSE YPC currently has no outstanding Notices of Violation from either EPA or ADEQ. All prcvious problems have been rectified.

28-42 The FElS does not adequately assess impacts of proposed increased timber harvesting during the caretaker status program. Annual harvests historically have ranged from 300,000 to 400,000 board fc,c.et and it is estimated that 442,000 board feet is the annual allowable cut to achieve a sustained yield, thc level at which removal is equal to growth. The FEE should assess the long term impacts of excceding a sustained yield.

IIIISI'ONSE: The Base Closure and Realignment Act requires that the Department of the Amy only coiisider the environmental consequences of the proposed closure of JPG and realignment actions to YI'G. 'l'hcs establishment of a caretaker status does not preclude the compliance of the base closure hw. Impacts associated with future reuse will be addressed in future NEI'A analysis and di)~cimcnt;ition.The Army will continue its sustained yield and multiple use management policy. 'l'iiiih*rmanagement will be addressed in the Natural Resources Management Plan. See response to ronlnlcllt 28-6.

2-43 Very little tree replanting has occurred within JPG. Reseeding occurs primarily by natural rtwc~p%ition.EPA recommends tree planting where this can be done safely at JFG.

KESI'ONSE: Prescribed burns only occur in designated areas. Increases in burning acreage are not iinticipnted.

28-45 The DEEstates controlled commercial harvesting of timber will continue during the caretaker pc-riod and adverse impacts on surrounding vegetation and aquatic areas caused by harvesting tcdmiques could be minimized by the following BMP. All applicable Soil Conservation Service BMPs shoulJ be included in the FEIS.

28-46 Timbering activities could adversely impact the smooth white violet, a State threatened species recorded within the installation boundaries. The DEIS states mitigative measures and species specific management plans could be developed following the species surveys. The FEE should prescribe to this course of action.

RESI'ONSE: The Army will comply with all applicable laws before timbering activities resume at JI'C;. See response to comments 28-6 and 28-42.

28-47 The DEIS states that clearing or extensive harvesting in wetlands during timbering could be avoided and that selected harvest will have far less effects. The DEIS also states that adherence to Section 404 regulations will result in avoidance and minimization of impacts to wetlands. Implementation of erosion and sedimentation controls and BMP's in forested wetlands would also minimize potential negative impacts on this resource.

28-48 'l'lie FElS should prescribe to selective cutting or avoidance if plant and wildlife surveys indicate thc potential presence of threatened and endangered species in wetlands or where erosive soils are p

2-41) 'I'IIv 1,'1(15 docs not provide sufficient information to adequately assess the impacts of the pio~~o~~dtlirccfold incrcnsc in limber harvesting at JlC The FEIS should include a map of the areas 1li.it will be opened to harvesting during the caretaker status program. This map should indicate topoi:r.ilhic rc*licf and show all major streams and their major tributaries and wetland areas including plustrinc forested wetlands and new access roads that would be required. The FEE should describe LIICiypc of eiliiipmcnt that would be used for felling and transport and special needs and procedures Iwc,iusc uf UXO contamination. The FEIS should indicate if timbering will occur in wetlands and if so will drcdgc and fill activities be associated with it. Mitigation must be provided for all unavoidable losses of wetland.

ItESl'ONSE: The Army will comply with all applicable laws before timbering activities resume at JPG. See response to comments 28-6 and 28-42.

28-50 Insufficient information is provided in the DEIS on the preferred realignment alternative at YX. It appears from Figure 3.4-4 in the DEIS that the area south of Pole Line Road where the ahernative direct firing line for DU and non-DU munitions is proposed is presently in an area free of UXO and DU contamination. One of our main concerns, which should be addressed thoroughly in the IXIS, is the potential for contamination of downrange areas at YPG with UXO. Therefore the figure requested above and accompanying text should also indicate the current extent of UXO, DU and beryllium in the proposed ranges and alternative range in the Kofa Range. If areas currently contaminated with DU and beryllium are indicated in a proposed new non-DU munition test range, the potential for and impacts of spreading DU and beryllium contamination as a result of non-DU munition impacts should be assessed in the FEIS. Also any adverse effects on possible future cleanup of existing DU, beryllium and UXO contamination as a result of added UXO and DU contamination from production acceptance testing should be identified and impacts assessed.

2-51 Tlic projccted effectiveness of a DU "catch box" system in preventing DU contamination of the i~siiiy,c-hsd on past experience should be discussed. The DEE does not indicate if the DU "catch box" \ydc,iii would he used if this testing is conducted north of Pole Line Road. The FEIS should indicate

Ihi, iir ot1ic.r mitigation measures that would be used for DU munition testing conducted north of Pole I .iw l

28-52 'The projected use of herbicides on PAT impact fields in terms of types, quantity and application r.ik ~l~ouldbe discussed in the FEIS. Potential environmental impacts and necessary mitigation iiicmiirc such as avoidance of wash areas should be discussed.

KESI'ONSE: Herbicide use is anticipated to be low due to the arid nature and sparse vegetation of the arcn, and will pose no significant impact to human health or sensitive species.

28-53 Five Federal endangered species may occur within the JPG property boundaries (four birds and on^ mammal). The habitat of the Indiana bat potentially exists within JPG. The Kirtlands's water snake is listed as a "Category 2" species under Federal review for possible listing.

IIESPONSE: These species have been noted in Section J.3.1.8.1,and Table J.3.1-4.

28-54 'l'hcre are 22 Indiana State endangered species known to exist or occur in the immediate vicinity of JPC property (eighteen birds, two mammals and two amphibians) these species are subject to protection provided under Indiana Law 310 3.1-2.7. Indiana State threatened species known to exist or occur in the immediate vicinity of JPG include two birds, one mammal, two amphibians and one rcytile

KLSI'ONSE: See response to comment 28-53

28-55 Surveys should be conducted for all Federal and State threatened and endangered species and rcwlts reported in the FEE. Mitigation plans should also be included for all affected species and ~riIic~iIhabitats.

28-56 'l'lic Ills states that the potential impact to wildlife resources would reduce because of cessation (11 ,ic.ttviti(%s.This statement does not take into consideration any current contamination of the site that IILIV IN> iiiipcting the wildlife and will continue until the cleanup of the entire base takes place.

It%<.it-.Vcry little potential exists for bioaccumulation of UXO constituents because of munitions are ~,~t.cl[ltilili.iiitlymetal parts that encapsulate high explosives with limited potential for chemical Ic;irhiiig. Animal tissue is monitored once a year for radioactive materials in conjunction with the annual deer hunts.

28-57 An ecological assessment is required for any RCRA corrective action investigations.

KESI'ONSE: An ecological assessment will be conducted on all RCRA-regulated areas requiring corrcclive action.

28-58 The FEE should also indicate what steps the Army will take after closure to ensure the continued protection the great blue heron colony and the three areas designated by the Department of Natural Resources as "areas of excellent natural community values."

HESPONSE: See response to comment 28-6.

28-59 A. The DEE states (page 4-4) that the lack of baseline data on benthic macroinvertebrate communities and water quality makes these impacts difficult to assess. The DES also reports only one of the ninny creeks has been surveyed for threatened and endangered species.

The DES notes the Eastern Sand Darter, a future candidate for Federal endangered species status is found in the area and could exist at JPG. It should also be noted that EPA biologists have collected the Harlequin Darter, a species thought extirpated from Indiana, in Graham Creek just west of Jl'C; near San Jacinto. We recommend that fish and macroinvertebrate surveys be performed to identify any existing stresses and to assess potential impacts from timbering operation to species and ;iqu;itic communities and develop mitigation measures. Because of highly erosive soils in forested wetlands along creeks at JPG, timbering in these areas have a high potential for adverse water quality and aquatic life impacts.

ItESPONSE: See response to comments 28-6 and 28-42.

28-59 B. The FElS does not adequately describe surface and ground water hydrology and conbiiiiniint migration potential from testing ranges and other sources at JPG.

KESI'ONSE: Contamination migration potential was adequately addressed in evaluating closure. 'I'lic ri5k for contaminntion from the testing ranges is very low.

28-00 Wc dis.igl-ee with coiiclusions in Section J.3.1.6.1Groundwater that secondxy porosity from Ir.ictui.ing and subsequent solution is poorly developed. The geologic and hydrologic characteristics of th*JIY; vicinity have been describcd most recently in the Remedial 1nvestig.Ition-Jeflel.son I'roving ~~i,i~iii~l-'l'echiiic;ilIkport AOll, prepnred by Environmental Sciences and Engineering, Inc., for the US Ainny 'l'oxic and t-lazardous Materials Agency (USATHAMA), June 1989. The hydrogeologicnl iiiforniation presented in this report is general and seems to accurately describe the regional hydrogeology. However, the information is not specific for JPG and cannot be assumed to be applicable to JPG or to specific sites within JPC.

RESPONSE: Ceohydrological information presented in J.3.1.6.1,describes the regional geology of which JI’C is a part and assumed to be applicable to JPC as a Regional Study. Local geohydrological conditions may be studied in detail as part of further consideration of determining extent of contamination under the Rl/FS and other monitoring requirements subsequently developed. 28-61 A bedrock lineament and fracture trace study performance at JPG indicate that surface drainage patterns arc, at least in part, controlled by these bedrock features and that there has been some dissolution of limestone and dolomite in the area. This is further evidenced on the topographic map by the presence of sink holes (karst topography) near Graham Creek and “Shonk Farm.” Therefore, it is concluded that surface streams and bedrock aquifers are hydrologically interconnected. There is insufficient information, however, to conclude whether the streams flowing across JPG are gaining water from or losing water to the underlying bedrock aquifers. Stream flow characteristics and hydrologies differ from place to place and seasonally throughout JPG.

RESI’ONSE: Comment noted,

28-62 To determine seasonal hydrogeological variations and to identify any contaminants that are entering/leaving the facility, stream flow rates and water quality should be monitored at facility boundaries. Groundwater sampling should include analysis for metals, herbicides, and explosive rcsiducs.

KESI’ONSE: Future studies will include groundwater analysis and water quality analysis of surface so~irceswhere appropriate. See response to comment 28-1.

28-63 Groundwater gradients, directions, and rates of groundwater movement and potential paths of pollutmt migration should be determined across the facility. The uppermost aquifeds) should be Jcfiticcl and the vertical hydraulic head distribution between aquifers should be determined at all solid wiiste management units and other contamination sites where groundwater quality should be monitorcd for metals, herbicides, and explosive residues to determine if the facility is contributing coiit,iiiiiii;ints lo the groundwater and if contaminants are migrating off-site.

2M14 Spcc.ifiL. knowlcdgc of local directions and rates of groundwater movement is limited. to three s11i;i11aI(*iis which have been separately investigated. These areas are the depleted uranium (DU)area, LiIs(i kiwwn iis tlic Delta Impact Area) which covers approximately 2 square miles; the Gate 19 I,iiitllill, ,about 20 acres; and the building 279 solvent disposal area, about 1 acre. The regional ~;10undwatcrgradient is indicated to be in a west to southwesterly direction, ultimately discharging ,ii~nh; ihr Ohio River. However, JPG reports indicate that groundwater gradients are to the west- iioriliwcst and south-southeast, respectively, at the Gate 19 Landfill and the building 279 solvent disposal arm.

ItESl'ONSE: Comment noted.

28-65 In the past, large quantities of 1,1,1 trichloroethane, paint thinner, and inert filler containing niethylene chloride have been disposed of at Gate 19 Landfill. Seven monitoring wells were installed from 1981-83 to determine if contaminants have migrated from the landfill to the groundwater in the iinmediate vicinity. Twelve additional wells were installed at various depths in 1988 to quantify dilfercnces with depth. Samples of groundwater from three monitoring wells contained bis 2- ethyllicxyl phthalate and the sample from one well contained acetone (6-2-10). Additional downgradient wells are required. EPA believes current well spacing is not adequate to assure clcicciion of downgradient migration of contaminants. Also, several wells are screened below the water table so contaminants at or near the water table would not be detected. Additional or rcplacenient wells should be installed and constructed to intercept possible groundwater contaminants moving at or near the water table.

RESPONSE: Comment noted.

28-66 'l'hrce groundwater monitoring wells were installed at building 279 and trichloroethylene rontamination of the groundwater was confirmed. Water table contours based on water level ~iiciisiirciiientsat three different dates indicate groundwater flow to the south and the southeast rather ili,iii to llic southwest as stated in the general hydrogeologic data. Interpretations are needed to cli;iraclc.rize groundwater conditions, including seasonal variations, throughout the facility. The (.xi~3tin~;lm-~ition and depths of the three monitoring wells are not adequate to detect any deeper iii\p(,rsion of n contaminant plume from the Building 279 solvent disposal area. Because it is uiikiiown how far contaminants have travelled downward in the saturated zone or in the bedrock, nionii(iring wells should be installed in the Building 179 area: one well screened at the till-bedrock inlcrf.icc .iJjnccnt to MW 15, one well 30 to 50 feet south-southeast of the solvent disposal area dry wt.11 111 tlic lowcr 10 feet of the unconsolidated aquifer.

28-67 Sm1pIing c1;it.i obtained for JPG's industrial storm water discharge permit application from the ~.,iiitonii1(mt,111~1 downrange areas should be included in the FEE. KESI'ONSE: Appropriate data will be included in the industrial storm water discharge application

28-68 lixceptionally high rates of application and large total quantity of the herbicide atratol are t,pirtcd in 'l',il+ J.3.l-5on p;igrs 3-30. Atratol is used for non-agricultural weed control, contains ,itrLi/.inc'IS a principnl active ingredient, and has three registered formulations as shown below.

Maximum Conc of Atrazine Labeled Rate I;orniu In1inn Related Materials % Ibs/acre

Atratol 8P 8.0 21 8

Atratol 80W 80.0 50

Atralol 90 90.0 11.1

Tlic rty?

The data of Table J.3.1-5are from 1980; more recent data should be provided in the FEE. The ,itrat01 product actually used should be determined in order to compute the amounts of active ingredients applied. However, the application as reported is above labeled rates for all products; even 11 Atr;itol XI' wereapplied (the lowest atrazine content), about 35 lbs of atrazine per acre would have bvcn applied; this is a rate more than 10-times the normal agricultural rate for this herbicide. At these r,itrs, );round water contamination from leaching, and stream contamination from run-off have high \wtvnlial. 'Iherefore, we recommend monitoring of groundwater, steams and soils near the heavy .\pplic.;i!iun areas; analysis for organic chlorine should be performed and, if Atratol 8P is involved, 'iiidlysis for boron (Atratol 8P contains 47% sodium metaborate). Remediation of highly contaminated viilc, ;ind/iir rroding soils may be necessary. In such an event, it might be in order to gain expert help \iic.Ii .is from a university that might be able to provide valuable data.

c I ~iiti(11 (.OIII~I Iitivti c-xccrded the manufacturt~r'srecommended limils. Since the fnrinulations

I,)nt,iiind Ali~,izini-and boron, Ihe sclicdulcd sampling will also include the Atrazine and boron ~iii,iIv~i~ill :i~ldition lo olher pesticides.

2X-(1') ILis~xton thc above datii and other pesticide iise information at JI'G, we also T~COIliIlieiid tiiollitoriiig siirfacc water, groundwater and sediment for bromacil, 2.4-D and 2,4,5-T, dinxins and forums. Depending on the area and extent of use, the environmentally persistent pesticides that have been used at JPGincluding DDT, heptachlor, and kepone should also be monitored in these media.

ILESPONSE: See response comment to 28-1

28-70 According to the Initial Installation Assessment at JPG, August 1990, roadways north of the firing line are not paved and "waste oils" were routinely sprayed on the roads for dust control. The specific identity or source of this "waste oil" is unknown. But the material was presumably generated on-site and may have contained spent solvents and PCBs. Roadway oiling stopped in August 1979.

RESPONSE There is no evidence of PCB-contaminated waste oils in unpaved roadways.

28-71 The DEIS does not adequately assess the potential for contamination of surface and groundwater from UXO, DU releases and any pesticide usage that would result from PAT at YPG.The FEE should provide this assessment including the results of any pertinent surface and groundwater studies performed at YPG. The statement on page 4-41 that "Chemical releases associated with cracked LJXO will be less likely at YPG than currently at JF'G, due to the lower potential for migration (DU is not soluble in water) should be explained and substantiated with available data. The potential transport of DU on suspended particulate in groundwater and resulting contamination of domestic and agricultural water supplies should be assessed.

RESPONSE: There is little likelihood for contamination of either surface or groundwater sources at YPC by either UXO, DU or pesticides. This is due to reasons summarized below.

Use of catchment facilities; Encapsulation of UXO in metal; and Local conditions (high evaporation rates, low precipitation rates).

Therefore it is unlikely that it could become soluble and leach chemical HE from encapsulated projc*ctileslo groundwater located 600' below the impact surface.

28-72 The Army should quantify "Depleted Uranium (DU) toxic levels" discussed on page 4-23 and indicate anticipated levels of pollution expected in aquatic resources.

ICESI'ONSE: See response to conimemt 28-71

28-73 The FEIS should commit to preparing the Erosion and Sedimentation (E&S) Plan_and Natural Resoiirces Management Plan identified in the DEE which provides preventative and mitigative iiiecisiire to address all potential impacts resulting from proposed increased timber harvesting at JPG. Wc rcconinlend the E&S Plan incorporate all applicable Soil Conservation Service Best Management I’rxticvs, Standards and Specifications for Indiana including those concerning removal of trees, site prc‘lxiraiion, woodland management and access roads. The Natural Resources Management Plan should assess the needs of non-game wildlife as well as game species.

I(ES1’ONSE: See response to comments 28-6 and 28-42.

28-74 The FEIS should also fully develop mitigation plans for areas of highest potential impact at YI’G, Le., lo wildlife, to air, to cultural/historic yesources; from hazardous waste, in various forms, and from noise. Given this is accomplished, the FEIS should not only identify impacts from specific actions but should also include more detailed plans to minimize those impacts to the fullest extent.

RESPONSE Comment noted. These measures have been provided in the document to the extent nerded to address realignment. List of Public Speakers Madison, Indiana Public Meeting June 24,1991

1. Susan A. Gilroy, representing Senator Richard Lugar.

2. Harold Gutzwiller, representing Senator Dan Coats.

3. Wayne Vance, representing Congressman Lee Hamilton.

4. Mayor Wooden, City of Madison, Indiana.

5. Robert J. Falls, Jr.

6. Mike Moore.

7. John D. Gay.

8. Greta Hawvennale.

9. Tom McClelland.

1u William Brown.

11 Mayor Wooden, additional comments.

12 Jack Wycoff.

13 Mike Moore, additional comments.

I4 Jack Wycoff, additional comments. JEFFERSON PROVING GROUND PUBLIC MEETING COMMENTS AND RESPONSES JUNE 24,1991

'The following are comments and the corresponding responses to issues raised during the June 24, 1991 ]PG DEIS Public Hearing located in Madison, Indiana

1 SUSAN ANNE GILROY, REPRESENTING SENATOR LUGAR

1-1 Issues raised during the Public Hearing by Senator Lugar have been addressed by responses in letter 5.

2 HAROLD GUTZWILLER, REPRESENTING SENATOR COATS

2-1 Issues raised during the Public Hearing by Senator Coats have been addressed by responses to written comments 5 and 7.

3 WAYNE VANCE, REPRESENTING CONGRESSMAN HAMILTON

3-1 Issues raised during the Public Hearing by Congressman Hamilton have been addressed by responses to written comments 1 and 8.

4 MAYOR WOODEN, CITY OF MADISON (EXHIBIT NUMBER 4 IN TRANSCRIPT3

4-1 This document does little more than mention the UXO contamination that will remain following Jl'G's closure. In fact, this 300 page document devotes only two pages to a discussion of the UXO issue. How in good conscience can the Army present this document as an accurate representation of the environmental consequences of the JPG closure?

RESPONSE The Army recognizes seriousness of the UXO concerns at JPG. Additional research is required to adequately address the UXO problem. This will be covered in follow-on environmental analyses. This EIS is not intended to plan a cleanup strategy. The Army is required to cleanup all areas posing a significant risk to human health or the environment. The Army is committed to protecting public health and safety.

4-2 The citizens of Madison deserve to know what the Army intends to do in order to reclaim this massive tract of land that they have contaminated. I believe a viable EIS prepared in good faith is the first step in insuring the public health and safety, not to mention the economic recovery of an economically depressed area, after the closure of JPG.

KESI'ONSL The reuse plan ultimately developed for JPG will be the subject of separate NEPA aiiCrlysesand documentation prior to the final disposal of the property. This plan will be coordinated with the public. The Army will not allow the UXO to become a hawrd to human health or the environment. The Army will take whatever measures are necessary to protect public health and the naliiral resources of JPG. . JI’G RESPONSE TO PUBLIC MEETJNG COMMENTS (continued)

4-3 This draft document only serves to confirm what the residents of Madison have feared all ala that the Army intends to simply close JPGs gates and walk away, leaving behind 55,000 useless acres This strategy and this document are both unacceptable.

RESI’ONSE: Retaining, fencing and securing the property is not an alternative desired by the Army. With the help of the local community, the Amy would prefer to develop a more productive reuse of the installation. The extent to which contaminated property is to be cleaned and the reuse of that property are mutually dependent. Planning for both must be an iterative process and the Army will continue to cooperate fully with the DOD Office of Economic Adjustment and the JPG Regional Development Board.

5 ROBERT FALLS, PRESIDENT, AFGE LOCAL 2797 (Exhibits area provided in transcript)

5-1 Issues raised during the Public Hearing, by Robert Falls, have been addressed by responses to written comment 11 from Mr. Falls, AFGE.

6 MIKE MOORE, JPG SURVIVAL COMMITTEE

6-1 Issues raised during the Public Hearing by Mr. Moore have been addressed by responses to written comments 12 and 16.

7 JOHN GAY, HOOSIER ENVIRONMENTAL COUNCIL

7-1 Issues raised by the policy resolution read by MI.Gay have been addressed by responses written comment 9.

7-2 I reviewed the EIS to find that it does little to identify the contaminants that are present.

RESPONSE: The information presented in the EIS concerning the types of known contarninants idcntifitd at JPG is based on existing data, primarily the Enhanced Preliminary Assessment.

7-3 Then it goes on to propose that they harvest more timber and increase the erosion and increase the probability that these contaminants are carried off site. I propose that the Army not do so.

RESPONSE: The Amy intends to prepare and implement an erosion and sedimentation control plan for JPC. Implementation of proper erosion controls would minimize the amount of erosion.

7-4 The Army just cannot be allowed to simply close this property and walk away.

ItESI’ONSE See response to public hearing comment 4-3 JPG RESPONSE TO PUBLIC MEETING COMMENTS (continued)

8 GRETA HAWVERMALE, BRANCH CHIEF, INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF ENVIRONMENTAL RESPONSE

8-1 The study does not propose a comprehensive environmental investigation of the site, particularly as it omits the significant portion for evaluation, that is the areas impacted by unexploded ordnance. This and numerous other technical concerns will be identified in greater detail in our written comments.

RESPONSE IDEM’S formal concerns are identified and addressed in responses to written comment 25.

9 TOM McCLELLAND

9-1 The law as I understand it says that the Base must be closed and the property sold. I am a bit confused. We’re going to take and sell JPG for $25 million, and we’re going to spend $112 million for construction at Yuma Proving Ground to do the same thing that we are doing at JF’G. And you have not come up with any kind of a dollar figure as I see for the cleanup of JPG,for it to be solk

RESPONSE The specific cost estimates for the environmental cleanup activities at JPG will not be known until the N/FS has been completed for the cantonment area and additional reuse information is prepared. This information will be provided in additional environmental documentation. See also response to written comment 4-21.

10 BILL BROWN

10-1 1s it the State of Indiana, or is the Army going to pay for the deaths of people who are going to get killed out here when this base is closed?

RESPONSE The liability for injury after dosure will be dependent upon the circumstances and determined through due process of law.

I1 MAYOR WOODEN, CITY OF MADISON

11-1 There is nothing closing JF’G down that goes along with the intent and closure of the law. That law has been changed with modifications and, as of today, the Army still has not given one, not 15, not three, not even one, legitimate reason for closing JPC down.

ItESI’ONSE: In accordance with the Base Closure and Realignment Act, this ElS does not analyze the decision to close JPG. JPG RESPONSE TO PUBLIC MEETING COMMENTS (concluded)

12 JACK WYCOFF

12-1 If indeed the Army does close JPG and with all intentions, they intend to do so, what intentions does the Army have to ensure that the same process doesn’t happen again in Yuma? How are they going to clean that place up as they go along? Are they going to do it again in 50 years, and who is going to suffer after they leave?

RESI’ONSE: The Yuma facility, as in JPC, is committed to all requirements regarding environmental regulatory compliance. Prior to the disposal of any property, Yuma or JPC, the Army must ensure public health and safety and is required to cleanup all areas posing a significant risk to human health or the environment.

13 MIKE MOORE (JPG SURVIVAL COMMITTEE)

13-1 Do you know anything about parceling up JPG, cleaning up portions of the facility and selling them.

RESPONSE Issues raised during the Public Hearing, by Mike Moore, have been addressed by responses to written comment 9-2 and your written comment 12-9.

14 JACK WYCOFF

14-1 Whose decision was it to do this ELS on the 3,000 acre cantonment area?

RESPONSE The EIS was not done on the 3,000 acre cantonment area. The Army decided to prepal, this EIS on the entire closure of JPG. CALL TOU FREE rnadbington. BC 20515 I8W1 092-3232 May 21, 1991

The Honorable Michael Stone Secretary of the Army The Pentagon Washington, DC 20301 Dear Secretary Stone: I am writing to express my concerns with the Army's recefit2.y reieased draft environmental impact statement (EIS) fo.r the Jefferson Proving Ground (JPG) in Madison, Indiana. I appreciate the efforts of the Army Corps of Engineers and other contributors who have sought to provide a comprehensive overview of the environmental and socio-economic impacts associated with the closure and realignment action. I am pleased that the draft EIS has finally been released and that the Army's proposed strategy for the closure action is now available'for public scrutiny. However, I am displeased with the conclusions and recommendations contained in the draft EIS. This report confirms for me and for the citizens of Madison and surrounding communities what we have suspected for quite some time: that the Army intends to close JPG and walk away from the enormous contamination problem on the property. I have several criticisms of the draft EIS which I trust will be considered and addressed during further consideration and revision of this document.

First, I 3m .-.c.Z.-.Q..

TwlS STATIONERY PRINTFOON PAPER HADE OF RECYCLED FIBERS -I- The Honorable Michael Stone Page 2 May 21, 1991 this property hinges on how and whether the Army intends to assess and clean up the UXO contamination. Second, I am also displeased that the Army will not study, let alone clean up, UXO contamination north of the firing line. The draft EIS notes that the Army will undertake a sampling program of selected sites and streams over the entire base to determine if contamination is hazardous to the public or the environment. However, Assistant Secretary of Defense Colin McMillen has indicate( in a recent letter to me that this program will not cover UXO contaninstioil nort!) of the firing line (May 10, 1991). This policy is disappointing and potentially dangerous to public health. The draft EIS states: "The presence of UxO represents not only the hazard of detonation 'if disturbed, but groundwater contamination could result if cracked shell casings release high explosive chemical constituents and white phosphorus. Unburned white phosphorus can remain viable under the ground for many years" (3-74). Clearly, the presence of UXO contamination ovei the entire base poses a long-term health risk to the surrounding population and environment. And yet, the Army's policy is not even to study the UXO problem north of the firing line. How can you justify this policy?

At the very least, the Army should conduct an extensive study of the contamination problem north of the firing line. The Army claims that it does not have cost-effective technologies to clean up the entire base at this point, but it certainly has the capability to prepare a comprehensive remedial investigation/feasibility study (RI/FS) of the entire base. An RI/FS would at least give the Army and the residents of southern Indiana an accurate assessment of the scope o€ the contamination, and a summary of potential remediation strategies. Third, I am concerned about the Army's commitment to clean up Lhe 3,000 acres south of the firing line. The draft EIS notes that the Army will initiate an RI/FS of this area in June 1991 and complete the w9rk by September 1993. I am encouraged that the timetable on the RI/FS has been shortened from three years to two years and that funding has been budgeted for the project in FY1991 and FY1992. What troubles me is that the Army has made no commitment to actually clean up the contamination south of the firing line. The draft EIS notes: "At the conclusion of the RI/FS a decision will be made regarding the cleanup of the south area based upon the t:nvironmental hazards identified, the resulting risks, and the i+ftectiveness of cleanup €or the desired future use" (2-13). I

-2 The Honorable Michael Stone Page 4 May 21, 1991

011 cleanup of contamination north of the firing line is incompatible with these alternatives. The draft EIS mentions locating a landfill in the northwestern corner of the base, and a correctional facility in the northeastern portion. How can the Army pursue these alternatives if it has no intention even to study the UXO problem north of the €iring line? I think the Army should clarify its position on this issue.

Fifth, I am concerned that the "caretaker status" proposed for the base will become permanent. The draft EIS suggests that there is a possibilicy tnat tne entire JPG property might be fenced off in perpetuity: "Due to long term hazardous waste contamination problems and the potential that unexploded ordnance could .be found virtually anywhere on the installation, it will not be possible to immediately dispose of all the property. As such, it will become necessary for the Army to establish a property caretaker status program once JPG is officially closed in FY95. All or part of the JPG parcel will be committed to a caretaker status and administered by the Army. A definite period of caretaker status has not yet been determined" (underline added; 2-9). I am left with the distinct impression that the Army is looking for the most inexpensive way of disposing,of the JPG property, even if this means putting the facility in "indefinite standby status." The Army has committed $5-6 million for the RI/FS on the cantonment area. It has committed to do nothing more than that. It seems content to fence off the property and pay the bare minimum for upkeep and maintenance of the facility, at least for the indefinite future. Under this arrangement, the JPG property would be of no use to anybody -- the Army, the state, and local public and private interests. This would be the worst possible solution. I recently attended the Fiftieth Anniversary of JPG, which celebrated the excellent work of its employees and the history of the communities that once lived on the land. Area residents sacrificed their homes, their farms, their churches and their schools for the greater good of the country in the early years of World War 11.

The decision has now been made that JPG is PO longer necessary to the defense of the country. I do not agree with this decision. JPG has been a good and productive plant, and I think it could continue to serve a useful role in contributing to this eountry's readiness needs. The draft €IS estimates that about 421 paid positions will be Mr. Glenn D. Murphy R.R. 5, BOX 245 Madison, IN 47250 June 13, 1991

Mr. James M. Baker U.S. Army Corps of Engineers P.O. Box 59 Louisville, KY 40201-0059 Dear Mr. Baker: I am writing to express my concerns with the recently released draft environmental impact statement (EIS) for the Jefferson Proving (JPG) in Madison, IN. Following are several comments/criticisms of the draft EIS which I hope will be considered and addressed in the final version of the EIS. ABSTRACT. "Environmental impacts are considered to be primarily beneficial due to the cessation of testing ordnance and disposal of hazardous materials at JPG. No additional environmental contamination will result due to the closure of J PG" . COMMENT: JPG, while open and operating, meets all environmental requirements; once JPG is closed, does not unexploded ordnance (UXO) become classified as hazardous waste and immediately become a tremendous adverse environmental impact for which there is not current solution? COMEIENT: The statement, "No additional environmental contamination will result due the the closure of JPG" does not appear to be true when one considers the above comment and the fact that additional contamination will occur at YPG when testing begins there.

EXEC SUMMARY. "The estimated cost of facility construction is $82.2 million. One time expenditures would be $30.4 million which would result in a total realignment'cost of $112.6 million".

COMMENT: The $30.4 million is YPG's one time Costs. There is an apparent omission of $23.3 million in JPG's estimated one time expenditures. Rightfully including JPG'S -2-

one time costs makes the total realignment cost $136.3 million I (see encl 1). TABLE 5-2 - Reference 5.4.4.5.11, Factor: Recreation Impact of Closure **Negligible”. COMMENT: JPG is number one in TECOM in recreation i person-days. Over 19,000 person-days of recreation (not counting deer hwting) vi11 be lost annuilly vhich in my opinion is not negligible. Following is a listing of CY 90 JPG recreation person-days :

Fishing 6,000 Camping 4,000 Old Timbers Lodge 4,000 Small Game/Turkey 2,000 Softball, Tennis, etc. 1,000 Sightseeing 900 Hiking 700 Picnicing 600 I Total Person-Days 19,200 As long as JPG is in caretaker status, all recreation activities should be continued for JFG active and retired employees. Para 5.4.4.5.3 - “One-time expenditures for housing assistance, worker placement, and other costs will total $6.0 mil 1 ion”. COMMENT: JPG’s personnel costs are currently estimated at $13.2 million dollars by TECOM. One-time expenditures for JPG are currently estimated at $23.3 million dollars which are excluded from the EIS. (see encl 1). I do not believe the decision to close JPG was based on sound accurate data. The EIS should contain all accurate applicable data. I request your consideration of my comments. Sincerely,

Glenn D. Murphy \ -c 0 0 May 31, 1991

Proving Ground, Indiana. It has been determined that the proposed closure will not adversely impact highways and '9 therefore, have no comments to offer on the draft EIS.

Sincerely yours,

E. V. Heathcock, Director Office of Planning & Program Development

By: Paul D. Quinn Environmental Specialist Route 2, Box 22 Madison, IN 47250 June 24. 1991

requirements and staffing needs should be addressed and this section expanded. Assuming the caretaker staff to be existing @ JPG workforce personnel, this staffing determination should be 6. Pg. 3-18: Terrestrial Ecology. while it is true that JPG's unexploded munitions contamination has precluded much of the installation from being inventoried, there is an opportunity to apply GIS and GRASS in helping to analyze the installation. There is no evidence that GRASS was used in any portion of the EX.

7. Pg. 3-19: Where fox is mentioned, this should be fox squirrel. While we have both red and gray foxes, both are relatively rare. Fox squirrels are abundant and squirrel hunting (7 I is very popular at JPG. 8. Pg. 3-19: Desianated mast producing trees remain uncut to provide food for wildlife. However, hickories, oak and @; I beech are cut when timber harvests are conducted. 9. Pg. 3-22: Birds. Due to favorable habitat conditions, JPG supports an abundant population of bluebirds and (!!I I two bluebird trails have been created. 10. Pg. 3-22: So as not to cause confusion about Graham Creek not being in Jefferson County, Professor Karns included the Graham Creek area (Ripley Co.) in hie Jefferson county Herpetological Survey so as to provide continuity in his assessment of species diversity.

11. Pg. 3-27: Again, the discrepancies in our woodland acreage points out the need for GIS and GRASS implementation. However, our estimated acreage of forestland is increasing not @; I decreasing as old fields revert to sapling stands. 12. Pg. 3-28: Under land management practices, JPG does little seeding or planting after prescribed burning. Normally, a variety of native and exotic vegetation come up quickly and do @ I provide wildlife browse. 13. Pg. 3-31: Unfortunately, JPG lost our funding for an endangered plant survey. Consequently, there are no immediate 0'I plans by the IDNR to conduct any type of survey. 14. Pg. 3-32: On the wetland acreage, since Old Timbers Lake amounts to approximately 165 acres, the 108 acre lacustrim figure leads one to question the overall accuracy of the acreage figures. Again, GRASS might help to provide more accurate data on the wetlands at JPG.

15. Pg. 3-42: I suggest adding D Road and the John Hunt Morgan monuments to the map. This is the route Morgan's Raiders ook during the Civil War.

16. Pg. 3-44: Oakdale School has been nominated to the National Register of Historic Places. We are currently awaiting the decision of the SHPO.

2 - // 17. Pg. 3-66: The state lottery system where a few drawn deer and turkey hunters are permitted to access JPG is subject to conditions specified in the MOA and does not involve fishing. DoD employees outside JPG are generally not permitted recreation privileges on post -- however, active duty and retired military personnel do have recreation privileges.

18. Pg. 3-68: In 1990, a waterline was constructed in the north end, supplying water to Old Timbers Lodge. JPG purchases this water from the Canaan Water Company.

19. Pg. 3-12: The unexploded ordnance situation at JPG should be the major focus of any further planning. With JPG*s tremendous natural resource base acting as an **attractive nuisance’*, it is certain that curious trespassers and poachers will illegally enter the installation. Someone will get hurt or die if security cannot be maintained.

20. Pg. 4-5: Cessation of the mission and ending of the prescribed burning program will also be adverse to the bobwhite quail population. Natural succession will result in more maple/ sweetgum stands which have minimum wildlife value. 21. Pg. 4-11: Under Land Use, it would appear that maintaining JPG in a caretaker status does not comply with the original legislation. The law said that the land was to be disposed yet there is little chance this will occur. How can this selective interpretation be rationalized? My overall comment is that while the draft EIS adequately documents JPG*s resource base as best as we currently know, it does reflect a general lack of understanding and awareness. How can we truly discuss impacts if we really do not know the resource nor what the plan really is? -- In that regard the document comes up short. Again, I appreciate the opportunity. Sincerely,

Kenneth G. Knouf

3 United Statu Senate WASHINGTON, DC 20510

Honorable Hichael P.W. stone Secretary of the Army The Pentagon Washington, D.C. 20301

Dear Secretary Stone: We are writing regarding the Draft Environmental Impact Statement recently released by the Department of the Army for Jefferson Proving Ground. The Department of the Army is undertaking this environmental impact statement study in conjunction with the Base Closure and Realignment Commission recommendations and with respect to the requirements of the National Environmental Policy Act. We have previously explained our displeasure that the Department of the Army had confined the current remedial investigation/feasibility study (RI/FS) to the cantonment area which comprises less than 3000 acres or 5% of the installation's 55,264 acre site. The cantonment area south of the installation's firing line will receive an RI/FS which will be completed prior to a reutilization decision. Substantial reutilization of JPG requires a comprehensive evaluation of the extent and nature of unexploded ordinance which permeates the complete facility. As we have stated in previous correspondence and meetings on this subject, the environmental reclamation of the 55,264 acres at JPG and the return of the property to economic productivity are major concerns to our constituents and the State of Indiana. We are interested in obtaining a clean-up strategy and a cost estimate for clean-up prior to the closure of this facility. We believe such information to be essential in understanding the Department of the &yps commitment to a responsible plan for an environmentally sound clean-up and the substantial reutilization of the installation.

- I3 - Page 2

The Army’s Draft EIS proposes to create a “caretaker status” which, due to significant environmental and legal liabilities, will require on-going operations of security and fire protection, limited administrative operations and controlled deer hunts and timber management sales programs. In essence, the.facility will continue its operations including most of the current activities with the exception of the munitions testing function destined for Yuma Proving Ground. In addition, the Draft EIS makes a bold assertion that new contamination of soil, groundwater and surface water resources at the facility will cease with closure. This statement is unsubstantiated and may mislead the general public about the environmental impacts of over 23 million rounds of munitions which have fallen at JPG. We are hopeful the Department of the Army will recognize the need to complete a clean-up strategy and cost estimate at JPG for the complete facility. Such a strategy and cost estimate are important elements in identifying the tfue environmental impacts present at JPG. The environmental impacts of closure of JPG have not been determined in the Department of the Anny‘s Draft EIS. We request your response to our concerns regarding the lack of a clean-up strategy and cost estimates in the draft EIS on Jefferson Proving Ground.

Sincerely,

Richard G. Lua Dan Coats A+%-United States-Senatpr United States Senator

cc: Susan Livingstone . Assistant Secretary of the Army

i STATEMENT OF U.S. SENATOR RICHARD G. LUGAR ON JEFFERSON PROVING GROUND DRAFT EIS JUNE 24, 1991

Over two years ago the Corps of Engineers, Louisville District, conducted a scoping meeting on the Jefferson Proving Ground in this same high school building. At that meeting I indicated a number of specific environmental concerns and an interest in a broad evaluation of the environmental hazard6 present at Jefferson Proving Ground. I would like to reiterate a number of my previous comments and my specific understanding of the actions proposed by the Department of the Army in the Draft Environmental Impact Statement. 1.) I encouraged "a comprehensive accounting of the quantity, location and types of environmental 'contamination' throughout the 55,000 acre site." The Draft EIS indicates the Department of the Army is only planning a Remedial Investigation/Feasibility Study of the approximately 3000 acre cantonment area, south of the firing line. In addition, the Draft EIS indicates "the Army will retain JPG property for an undetermined amount of time" with "no current plan for conducting a remedial investigation of the entire installation". In fact, the Department of the Army proposes something called a "caretaker status" which almost insures non- use of 95% of the available installation to reutilization. This is simply unacceptable to Hoosiers and an inappropriate exit for the Department of the Army from this facility. 2.) I asked in 1989 for "a candid explanation of what we do not know" including an "attempt to estimate the quality and location 0 of additional contamination." The Draft EIS provides no such explanation. Unfortunately, the Ilraft EIS asserts in Table 5-2 on page S-5 that additional contamination to soils, groundwater and surface water will cease with the closure of the facility. This is an impact of closure which has limited basis in fact. The detailed environmental data that a full Remedial Investigation/Feasibility Study would Page 2 develop will confirm or deny this assertion. We need to know what the Army is proposing to leave as a legacy to Indiana; we need facts not assumptions. 3) I encouraged an evaluation of both the "likely uses of the site and explanation of the environmental suitability for such I 11ses " . Of the potentially viable alternatives considered, the regional landfill, general aviation facility, and the correctional 0 facility all require additional specific environmental investigation and assessment. The Draft EIS suggests that "restricted use" presents the most practicable and realistic means of reuse. However, the data will be obtained in a detailed analysis at some future, as yet unspecified date. We need to know before closure, the extent of contamination at JPG. 4) I suggested an analysis of the technology and funding I available to address each 'environmental liability' identified. The Draft EIS suggests the creation of "caretaker status" and indicates the "potential for unrestricted use of JPG is not considered feasible on the basis of existing technology and resource availability". This would lead one to conclude that an indefinite timetable and availability for future resources to promote reutilization results in no reuse for the overwhelming majority of this facility. 5.) I indicated the need for a plan to maintain appropriate A security at the facility after closure has been completed. The Draft EIS acknowledges that the Department of the Army must continue to provide low-level maintenance, fire and policing security protection, low-level administrative functions, controlled deFr hunts and natural resources management such as timber cuts, and maintenance of historical and cultural resources. The personnel and budget requirements for these continued operations under "caretaker status" have not been identified.

. Page 3

It is clear from even a cursory evaluation of the Draft EIS that the Department of the Army has provided minimal data and analysis of the areas where over 23 million rounds of ammunition have been fired over the last fifty years. The Department of the Army has provided a very limited commitment to clean-up and reutilization of 95% of this facility based upon'its creation of the caretaker status which mothballs the facility indefinitely and provides only hope that clean-up resources will be provided in an, as yet, unspecified time period. 'This is simply unacceptable and an action which undermines the intent behind the Base Closure and Realignment Commission process - to reduce Defense Department base support in both number and operational support costs and to reutilize the closed facilities for the benefit of the local economies facing the base closures. These goals have not been achieved at Jefferson Proving Ground. It is a simply a shell game with significant future costs for the Department of the Army: from the $112 million in new outlays for facilities to be built in Arizona at Yuma Proving Ground which will replace the existing Jefferson Proving Ground operation to the yet undetermined millions necessary to restore this land to complete reutilization by the citizens of Indiana. Page 2 JPG Senator Dan Coats

The Department of the Army has not indicated a plan for the remedial investigation/feasibility study of the area north of the JPG firing line. The creation of “caretaker status“ for JPG almost ensures non-use of a major portion of the facility. This non-use or non-utilization of substantial portions of the facility does not comply with the spirit of the 1988 Base Closure and Realignment Commission Act. Reutiliztion of the facility for economic development activities is of essential interest to the communities surrounding JPG.

I have requested several photographs of unexploded ordinance from the JPG personnel for use in the final environmental impact statement. I am requesting that the Department of the Army include several photographs of the unexploded ordinance in the final EIS in order to provide the general public with a visual description of this problem. It is a serious concern to which the Department of the Army has provided limited evaluation in the Draft EIS. I also continue to assert the need for a clean-up strategy and cost estimate in the EIS. I believe the inclusion of this information to be substantial enhancement to the EIS.

I am also very concerned that the Department of the Army has not forwarded a copy of this draft EIS to the Nuclear Regulatory Commission for review. Upon closure of the facility, the Department of the Army is required to submit a plan for decontamination and decommissioning of the depleted uranium license issued under the authority of the Atomic Energy Act. Although brief mention of this process is made in the draft EIS, no timetable, cost estimate or strategy for complying with this requirement is made.

The restoration and productive use of JPG is an important goal for all Hoosiers. The costs for clean-up are substantial, however, I believe the Department of the Army has acknowledged responsibility for the facility and its acknowledgement should be combined with a reutilization plan that broadens the proposed uses beyond a correctional facility, general aviation airport and/or regional landfill.

In conclusion, I must encourage the Department of the Army to revisit the issue of a clean-up strategy and cost estimate for the Jefferson Proving Ground in the area north of the firing line. I also believe there continues to be a need to evaluate the use of the facility by private corporations and government contractors for the same or similar work performed by the Department of the Army. If JPG is to close, ~oosiersare deserving of a better departure by the Department of the Army. THE HONORABLE LEE fl. HAMILTON Statement betore the

U.S. Army Corps OE Engineers Madison, Indiana

June 24, 1991

Col. Peixotto and members of the panel. Thank you for providing me with an opportunity to discuss with you the Army's recently released draft environmental impact statement (EIS) for the Jefferson Proving Ground (JPG) in Madison, Indiana. I appreciate the efforts of the Army Corps of Engineers and other contributors who have sought to provide a comprehensive overview of the environmental and socio-economic impacts aeeociated with the closure and realignment action. I am pleased that the draft E19 has finally heen released and that the Army's proposed etrategy for the closure action is now available for public scrutiny. However, I am displeased with the conclusions and recommendations contained in the draft EIS. This report confirms for me and for the citizens of Madison and surrounding communities what we have suspected for quite some time: that the Army intends to close JPG and walk away trom the enormous contamination problem on the property. I have several criticisms of the draft EIS which I trust will be considered and addressed during further consideration.and revision of t.his document. f.'irst,I am astounded that this several hundred page report ~irovidcsonly a cursory discussion of the contamination caused by 11111.xp1odedordnance (UXO) at the base. As the draft EIS concludes, "tt1+, level and extent oE the impacts from existing UXO's are unknown 1,111 represent the single greatest concern at the site. No area could bv rtrleased without a survey and, if necessary, clearance of UXO's" (4- Ill). The discussion of the UXO problem ends there. I am well aware thak the EIS is not intended to revleu actions or iiiipJcicts associated with potential remediatlon activities. But it :;~~.IIIsto me that the OXO problem lies at the heart of the matter. The r:iilqle greatest environmental impact of this closure ie the creation of ;I ',',,264 acre hazardous waste site outside of Madison, Indiana. I am very surprised to read in the draft EIS that closing the base will have beneficial environmental impacts (as the Army will no longer add to the conr.amination at the base). The future of this property hinges on how and whether the Army intends to assess and clean up the UXO contaminat ion. Second. I am also displeased that the Army will not study, let alone clean up, UXO contamination north of the firing line. The draft [.:IS notes that the Army will undertake a sampling program of selected sites and streams over the entire base to determine if contamination i hazardous to the public or the environment. However, Assistant Secretary of DeEense Colin McMillen has indicated in a recent letter to me that this program will not cover UXO contamination north of the firing line (May 10, 1991). This policy is disappointing and potentially dangerous to public health. The draft EIS states: "The presence of UXO represents not on1 the hazard of detonation if disturbed, but groundwater contamination could result if cracked shell casings release high explosive chemical constituents and white phosphorus. Unburned white phosphorus can remain viable under the ground for many years" (3-74). Clearly, the presence of UXO contamination over the entire base poses a long-term health risk to the surrounding population and environment. And yet, the Army's policy is not even to study the UXO problem north of the firing line. How can you justify this policy? At the very least, the Army should conduct an extensive study of the contamination problem north of the firing line. The Army claims that it does not have cost-effective technologies to clean up the entire base at this point, but it certainly has the capability to ' prepare a comprehensive remedial investigation/feasibility study (RI/FS) of the entire base. An RI/FS would at least give the Army ana the residents of southern Indiana an accurate assessment of the scope of the contamination, and a summary of potential remediation strategies. Third, I am concerned about the Army's commitment to clean up the 3,000 acres south of the firing line. The draft EIS notes that the Army will initiate an RI/FS of this area in June 1991 and complete the work by September 1993. I am encouraged that the timetable on the RI/FS has been shortened from three years to two years and that fundir has been budgeted for the project in FY1991 and FY1992. What troubles me is that the Army has made no commitment to actually clean up the contamination south of the firing line. The draEt EIS notes: "At the conclusion of the RI/FS a decision will be made regarding the cleanup of the south area based upon the environmental hazards identified, the resulting risks, and the eEEectiveness of cleanup for the desired future use" (2-13). I interpret this comment to mean that the Army may eventually decide not to clean up khese 3,000 acres. The JPG Enhanced Preliminary Assessment (USATHAMA 1990) listed numerous environmental problems south of the firing line, including UXO contamination. I would like more assurance from the Army that it will proceed with the-cleanup, even with this contamination problem. Fourth, I have some concerns about the Army's position with

-2 I respect to the reuse options listed in the draft EIS. The document discusses four potential alternatives, including: (I) like-kind use; (2) general aviation facility; (3) regional landfill; and (4) correctional facility. I am pleased that the Army is giving serious consideration to future use of JPG property and is committed to work wilh local leaders to craft a satisfactory reuse plan for the base and Lhe surrounding communities. I want to comment upon the four reuse proposals contained in the draft EIS. The document notes that "like-kind use offers an optimal reuse potential given the existing conditions at JPG, including the level of contamination'' (2-16). I agree that a government-owned, contractor- operated (COCO) or lease arrangement has merit. It would not entail a significant change from current operations at the base, and might remove the problem of ordnance cleanup. However, the Army has been reviewing this alternative for some time, and has raised concerns that it might not comply with the provisions of the 1988 Base Closure Act. Secretary McMillen told me in an April meeting that he did not think it likely that the Department o€ Defense would approve like-kind use of the facility. It would be helpful to me, to the local reuse committee, arid Lo other interested parties if the Army issued a statement for the record whether the "like-kind" option is legal. It is difficult to make progress on a reuse plan for the base if the Army and the Defense Department are giving mixed signals on this reuse 'alternative. I agree with the draft EIS that it makes sense to consider using the air facility at JPG, whether through the FAA-sponsored initiative or through another arrangement. Yet, according to the draft EIS, the airfield has not been used for over twenty years and would likely require repair and improvement. The document also states that the Army would have to conduct an environmental remedial RI/FS to determine the amount of contamination at the site. I trust that the Army will study this proposal more vigorously. I also agree that proposals to release portions of the JPG property for a regional landfill and/or a correctional facility may have merit. Southern Indiana is running short of available landfill space, and state and local governments are looking to construct new prisons. However, it seems to me that the Army's general position The 011 cleanup of contamination north of the firing line is incompatible witti these alternatives. The draft EIS mentions locating a landEill in the northwestern corner o€ the base, and a correctional facility in the northeastern portion. How can the Army pursue these alternatives iT it has no intention even to study the UXO problem north of the f'iriiig line? I think the Army should clarify its position on this 1 :;sue.

Fifth, I am concerned that the "caretaker status" proposed for the base will become permanent. The draft EIS suggests that there is a possibility that the entire JPG property might be fenced off in perpetuity:

"IJU~ to long term hazardous waste contamination problems and the potential that unexploded ordnance could be found virtually anywhere on the installation, it will not be possible to immediately dispose of all the property. As such, it will become necessary for the Army to establish a property caretaker status program once JPG is officially closed in FY95. All or part of the JPG parcel will be committed to a caretaker status and administered by the Army. A definite period of caretaker status has not yet been determined'' (underline added; 2-9). I am left with the distinct impression that the Army is looking €or the most inexpensive way oE disposing of the JPG property, even if this means putting the facility in "indefinite standby status." The Army has committed $5-6 million for the RI/FS on the cantonment area. It has committed to do nothing more than that. It seems content to Pence off the property and pay the bare minimum for upkeep and maintenance of the facility, at least for the indefinite future. Under this arrangement, the JPG property would be of no use to anybody -- th Army, the state, and local public and private interests. This would b the worst possible solution. I recently attended the Fiftieth Anniversary of JPG, which celebrated the excellent work of its employees and the history of the communities that once lived on the land. Area residents sacrificed their homes, their farms, their churches and their schools for the greater good of the country in the early years of World War 11.

The decision has now been made that JPG is no longer necessary +-, . the defense of the country. I do not agree with this decision. JP( has been a good and productive plant, and I think it could continue co serve a useful role in contributing to this country's readiness needs. The draft EIS estimates that about 421 paid positions will be eliminated; over 1,200 people will leave the region; income in the area will drop by $17 million and sales volume by $47 million. And, if (.he recommendations of the draft EIS are carried out, the residents of southeastern Indiana will be left with over 55,000 acres of property that is largely unusable. This is not a reasonable or just solution. I believe the Army tias a responsibility to leave the land as it found it -- uncontaminated, and available for public and private use. Anything less ignores the Army's responsibility to be a good steward of the Land, and is a disservice to the residents of this area and the COllIl t ry . I would be happy to answer any questions you may have.

- 23 HEC Policy Resolution on the Jefferson Proving Ground Whereas, Jefferson Proving Ground, a 55,000 acre ordnance testing facility in southeastern Indiana operated by the U.S. Army, is scheduled to be closed by 1995; whereas, Jefferson Proving Ground is heavily contaminated by unexploded ordnance, hazardous waste, depleted uranium shells, and solid waste, representing a significant threat to human health and the environment both within and nearby the facility; Whereas, the mostly forested 55,000 acres of Jefferson Proving Ground constitute an ecologically important natural resource because of the significant size and contiguous character of the site; Whereas, Jefferson Proving Ground is presently home to or at some time used by a wide variety of wildlife species, including many that are rare, threatened or endangered; and in the long term represents a potential major contribution to the need for large tracts of continuous forest to benefit forest-dependent species; Therefore, be it resolved by the Board of Directors of the Hoosier Environmental Council on the 23rd day of March, 1991, that: 1. The chemical and solid waste contamination at Jefferson Proving Ground should be cleaned up to the extent that all present or future threats to surface water, groundwater, and air quality are reduced t ough surface cleanup to maintain the goals of paragraph #SF Priority should be given to all landfill rites and uranium oxide contamination sites, which . should be cleaned up to meet the standards of CERCLA. 2. The JPG site shall be maintained intact as one property, managed by a federal, state, or private agency with natural resource experience; 3. The U.S. Department of Defense maintains full liability for all cleanup costs and environmental damages, and the WD retain8 permanent responsibility for security, safety and environmental monitoring, whatever the final disposition of . the property; 4. The future management of the site shall be designed to enhance its character as continuous, mature forest habitat, with restored natural drainage, and that only management activities that do not conflict with this objective are allowed; specifically, commercial timber management or other resource production activities are not considered appropriate. 5. The WD shall provide for the ongoing and permanent pKaCLiCr ui aibuinaimg or uiniuiziaig the snort and long term risk of environmental contamination from ordnance testing activities, and recover promptly all ordnance. Attested to by Albert Tinsley, Secretary, this 23rd day of March, 1991. i, . Albert Tinsley (j June 24, I991

To the Base Clooure Committee. the Secretary of Defense and any other affiliatee inslrumental in the cloeing of the Jefferson Proving Ground.

For the following reasons the cloaing of the Jefferson Proving Ground would be a mistake, an error in Judgment, an unbelievable miscalculation and an unheard brand of reasoning.

I. The Jefferson Proving hound has been loca tad here for the past 50 yeere.

2. It is centrally located and more ~cc9esableto a11 points of the U.S.A.

3. It hn r done a fine job throughout the years, far better thnn its eister Installations at Aberdeen, Md. and Yma , Arizona.

4. The acreage is contaminated with unexploded ahells and bombs end is completely unusable for any other busineer or activity . 5. It would take years and millions of dollars. perhn pa billions, to clear the area and make it safe for other activities. 6. The purpose of this clonrre war to snve money but with the clean up, the cost of moving nnd the bJilding of facilities at Yunu to nccommodats this operation makes this move a sham from every angle thnt you look at it.

7. The General Accounting Office report and investigation shows thnt erronoui and fla wed information was used to sake this decision in the firrt place.

8. It is stated that no bas can be taken off thir list without all being removed. To let a technicality like this prevent this base from staying open nnd waste n11 thnt money is sickening and unthinka ble.

9. To close this base and not clean it csmpletely woJld not be acceptable to the Citizene of this community or the texpayere throughout the country.

Ldts get off our political rears and do sosething right for a change.

Submitted by a Tax payer, a concerned Citizen, a former employee of Jefferson Proving Ground and a Voter. Anrerlcan Federatlon of Government Employees Local 2797 US ARYY JLFFt!RSON PROVIW QROUND AFGE TO DO COII UL WTWMIW NONE CAN DO UADISON. INDUNA 47260 FOR HIMSELF.

AFL CIO

- 011 Uecernlser 29, 1988, the Defense Secretnry's

tu look iiilo any cnvironmentnl problems irt I~IC.cltts~crr c~r

any bases. This to 11s seems In lie an ca3y wax niit ror Ihm:

but lhey did in lllc case of Fort Mollroe. Vh. A mrmlwr uT

the Commission loured the site stid after l'itdinp Ihnl Civil

Tlir Arncvicnn laxpayers will now nl sunie [IOI~IIIhrvc to

fool llie bi I1 In clcntl up 55,265 acres

erouiid iii Indiana. A1 the same lime, they wi I1 111su be

ob1 iaalecl lo clean lip another GO square uiiics IJ~.\meric:nn

soil in Arizona. Tllc co:;l of tnlal cleanup ai Jcl'rersoll

Proving Ground S expectcd to bc nrould Sir Ui I I iult

(SG.OOO.OOO,OOO 1990 dullars, arid LIic cleallup a1 Ytma is

IIO I kiiuwii a I 111 s lime, but will in all Iikelihoucl IBe

grealcr in lhe end. Pruviiiy Ground iii Arizoiia. The Army lias i:Iioseii to igiiore

the need Tor molBilization facilities lie type at

JcTfersori Proving Ground. For every war is 1101 I ikir Ilic

last war. Every war wc have rough1 iii s nce 1776 has beeii

different. Desert Storm was one of fast aclioil ai111 Iiigli

tecliiiology, ye1 niniiy or tlir muiii tioiis that were iisr,l IJ.~oui

armed forces have had samples tested at Jefferson Proving

Grouiid. And, it dnesii't slop lliere! Maiiy of our allies'

ammuni lion is lesled by JefTerson Proving tiroiiiid.

I have read llie Environmental Impact Slalement Dra I

and came lo the conclusion that it is n "piace or lrash

It fails to address the pi.oblems of 55.2C4 acres of

contaminated ground; the conlamiria t iuri being twenty three

mi I1 ion (23,UllO,UUU) unexploded rounds of ordnance. The

study fails tu address the problem ul cleailup of any

muiiitions in the entire reporl. It ,tries to deal with the

I approximately 3.000 acres in lhe south eiid of the Proving

Ground. but fai Is to take into account that numerous "dumps"

and test areas are or have been located therp. I1 fails lo

address the Tact UT costs. It does not actdress the idea of

what i I no move s made and everylliing stays llie same. This

:ilioii Icl have been used as a benchmark in llie report. But,

llie Corp failed o use it as a situation to cxaairre.

llnw muclr money woulcl lie saved if iio move was made? Hur

miifiy acres of laid would not be coiitaniiriatrd? llow iuaiiy

niiiiiiiils. plaii!s. and ancieiit sites ili aii cctllogical ly .

frnui lc rnviroiiiiieiit would riot IJ~disturbcd by uioviily the

mission lo Yuina Proving Ground ani1 closiiig JrTTersiiii Pruviiig

Gr~iiiiiil.

The IIKAC 88 Commission reconimeniIeiI tliat Jof frr.:oii Proving Ground be closed and sold for Twenty-Five Million Dollars (S2~.000,000.00). If this is the law and cannot be changed, then why is there a double standard when it comes to closing and selling? The Army plans to close Jefferson

Proving Ground and move the mission. But by this plan. they will place it in a caretaker status indefinitely. If you can not do both, then the law is broken and needs to be fixed. Congress can fix it. The .Army can ask for it to be fixed. The President can ask for it to be fixed. But, they are all failing to look up and see the light.

Thomas Baca, Deputy Secretary of Delense, told the

Senate Armed Services Subcommittee on Friday that One

Billion Dollars (f1,000,000,000.00) was needed to cleanup the eighty six (86) facilities already ordered to close for their eventual sale. The Department of Defense on Friday also asked the same Subcommittee that they be allowed to sell off bases before they are cleaned of hazardous waste.

If this is permitted, then, 1 wonder what homeowners' insurance will cost for a home ten (10) miles north of us tonight. That area is the DU Impact area. Sot only are DU rounds there, but HE rounds dating back to Norld War 11.

A11 or these twenty three million (23,000,000) rounds would be left layiny there. .. and the land could be sold ''u Is".

This is something I feared t.*o and a hal: years ago., The

1.1~s,ind regulations state that the land has to be cleared berure any sale of the land. .

i ~~~t~~.~lDkt?tt, take tilir fIUlr I,! 'j..k .AII .yt.lu 11cI.c luiiighl to write to your elective congressional rt,prrsentat ives tu oppose any cIi.iii~e in the laws to allu:v tlie .;AI,, of lantl I,? tllr DP~).I~~~~ICII*nr r:ef.*.>.- l!dl'.ira it I?. c -1 AFCE Local 2791 ,?--?, I i,i'i5+ib i'2 d l"jUtL>:.l ?,:,, $1 7 2 j ;> JPG SURVIVAL COMMITTEE TESTIMONY FOR THE DRAFT ENVIRONMENTAL IMPACT STATEMENT HEARING JUNE 24, 1991 MADISON, INDIANA 1. EXECUTIVE SUMMARY I want to thank you for the opportunity to address the CORPS of Engineers on the Draft Environmental Impact Statement. I am particularly happy to address COL David Peixotto, CORPS of Engineers, Mr. Mike Early, Test and Evalua- tion Comnand, and Mr. Robert Jameson, Army Materiel Command because of the roles played by their respective offices in the closure of JPG. We are here tonight because the Base Closure Commission of 1988 decided that the Government could save money by moving JPG's mission to Yuma Proving Ground, Arizona. To quote Governor Evan Bayh on his views on the Commission's actions: "they thought they were going to save money, they are not going to save money, its going to cost more money to close JPG. I am here today to critique the Draft Environmental Impact Statement, but first I want to place this document into a historical perspective. Jefferson Proving Ground (JPG) was designed and created by the War Department in the late 1930's to test fire ammunition and bombs being rapidly produced by Ameri- can Factories, as the nation prepared for war. During World War I1 no battlefield or city received more bombs or artillery shells than the 52,000 acres in Southern Indiana. These thousands of acres spread out over three counties have been savaged for more than 50 years by the most deadly devices created by mankind. Ghengis Kahn and his mongol hordes could not ravage a country side so effectively. Two thousand people were bodily moved from their ancestral homes in a period of 30 days. Today the only trace of these once prosperous and happy people are 36 Solid Waste Management Units (SMU's) and foundations of houses, barns, churches, etc. The 36 SMU's, by the way, are the basis of the one time closure costs of $57 million first submitted by TECOM. I have obtained transcripts of the minutes of the BRAC I 1988 Commission under the Freedom of Information Act. Using these transcripts, GAO documents, and the just released Draft Environmental Impact Statement, I wish to define the cost data for you that the GAO called flawed. It is amazing that the Pentagon and Congress have not asked for clarification of this "flawed data". It is my intent to explain why the GAO says the data is flawed and to relate the actions and responsibility of the U.S. Army Test and Evaluation Command (TECOM), the Army Materiel Command, and the BRAC I Commission. The GAO stated in its November 1989 report that the Secretary's Commission on Base Realignment and Closure used flawed data and drew erroneous conclusions that resulted in JPG being placed on the closure list. The GAO found that in the case of JPG the Commission erred by:

- Understating construction costs to transfer JPG's mission to hma Proving Ground, Arizona, by nearly 200 percent.

-1- -2 7 - Not including environmental cleanup as a cost of closure. This cost was conservatively estimated by the CHZM Hill study commissioned by Governor Bayh at $550 million, for surface cleanup only.

- Including proceeds from the sale of land in calculating the amortization period for closure. The GAO found that due to widespread ordnance contamination, it is unlikely that any of JPG's property could be sold.

The Survival Committee believes the bottom line is that if complete data had been used by the Base Closure Committee, JPG would not be on the closure list and the State of Indiana would not be faced with the prospect of 55,000 acres of Hoosier real estate rendered useless.

A quick review is in order here:

Public Law 100-526 (Defense Authorization Amendments and Base Closure and Realignment Act) states in part: "The Secretary shall:

(1) close military installations recomnended for closure by the Com- mission and (2) realign all military installations recomnended for realignment by such Conunission.

The Secretary accepted ALL of the recomnendations on January 5, 1989. On January 12, 1989 the Chairman and Ranking Minority Members of the Senate and House Committees on Armed Services asked the GAO to review the Commission's methodology, findings, and recomnendations. GAO's review focused on realignment and closure recornendations for 15 bases that represent about 90% of the Conunission's estimated annual savings. Let's review the GAO findings on 2 of the bases.

The BRAC I Comnission reported that the closure of JPG would save $6.6 million annually and the one-time closing cost would be paid back in 6 years. GAO, however estimates savings of $6.3 million annually (TECOM now estimates 13 million will be saved) and a payback period of between 38 and 200 years, depending upon the extent of environmental cleanup. The Comnission recomen- ded a major realignment of Forts Devens, Meade, Huachuca, and Holablrd. It estimated an annual savings of $21 million and costs would be paid back immediately. This is in contrast to GAO estimates of annual savings of $8.1 million with payback periods of 43 to over 200 years.

The Secretary of the Army, Michael Stone has testified before the Base Closure Conunission that it would not make sense to carry out the realignment of the Information Systems Comand from Fort Huachuca if it took from 43 to 200 years to recover the costs. Mr. Stone is presenting 7 modifications to the BRAC I Public Law because of mistakes made by the BRAC I Commission. The JPG Survival Committee states that these modifications are flagrant deviations from the Public Law 100-526 which was written in such a restrictive Janguage that no mistakes can be corrected.

-2- The payback periods for Fort Huachuca and JPG are uncertain. The payback for JPG is uncertain because the costs for cleaning up or managing the unexploded ordnance problem depend on the course of action taken. Now Fort Huachuca has been removed from the list. JPG remains on the list. DOUBLE- STANDARD? Yes. If it does not make economic sense to carry out the realignment of Fort Huachuca, then it does not make economic sense to close JPG. Representative Les Apsin, Chairman of the House Armed Services Committee, held a press conference on base closure Friday, April 12, 1991. He referred to a previous Conunission (BRAC I) and mentioned that commission had erred. The current Commission (BRAC 91) has the opportunity to correct errors made in BRAC I. We agree with Congressman Aspin. Apparently so does the Department of the Army since it has asked for 7 modifications to the BRAC I Public Law. DOD cannot sell the Presido and has stopped the realignment of the Information Systems Conand from Fort Huachuca to Fort Devens. DO0 cannot sell JPG without a 55 billion cleanup tab. So what shall it be? Close the most productive ammunition testing center in the country and cripple the Army's capability to mobilize for war? I offer these comments on the Draft Environmental Impact Statement. In my view this draft is not environmental! It does not discuss the impacts! It is not a statement! In the Public Scoping Meeting on June 8, 1989, the major area of public concern related to the amount of explosive and unexploded ordnance and its cleanup, other hazardous materials and wastes, the potential for reuse, and some concern for the wildlife. Apparently the unexploded ordnance and deplet- 0 ed uranium are of no major concern to the government. Ninety-five percent of the land is contaminated by unexploded ordnance, yet only a page and a half of the Draft Environmental Impact Statement is devoted to this issue. At this time I would like to call your attention to an article that ran Saturday, June 22, 1991 in the Madison Courier. (See Exhibit 1). I really expected to see photographs of the types of munitions laying out on the impact fields. I expected maps of JPG showing the impact fields and a listing of every type of munitions tested on JPG since 1941. There is not even a discussion about clearing the unexploded ordnance from the south end which is not clear of unexploded ordnance contamination. (See Map, Exhibit 2.) In my mind, I expected a document that could be used for reference material to aid future generations in cleaning up JPG. I expected a document that would illustrate to the residents of Arizona what an environmental nightmare that they can expect in the future. How can they plan for a reuse of Yuma Proving Ground when it is no longer needed by the Armv? What we received here is a oerfunctorv. fill in the blanks document I that do& not satisfy the legal requir'ement of the base closure law and in no way helps society now or in the future. This Draft Environmental Impact Statement can now join a long list of documentation that is based on flawed data and cursory "seat of the pants" analysis, a house of cards so to speak. Senators Lugar and Coats are not pleased with this Draft EIS and at this time I will introduce a letter signed by both. (See Exhibit 3.)

-3- @I 11. COST ANALYSIS. "I It is our understanding that a number crunching base closure software package was used to calculate the closure criteria for each base. This package of algorithms would take data submitted by the services and spit out data. It was the old "garbage in equals garbage out" syndrome. The major subordinate Field Comnanders submitted cost data that was at best a "seat of the pants" analysis based on 11-year-old data concerning cleaning up 36 well or land fills. The BRAC I Conmission then ran the data thru the algorithms until it gave them the answer they wanted. For example, from a GAO letter to Congressman Hamilton dated June 1, 1989:

A. The Cost to Construct New Facilities at Yuma (GAO June 1, 1989) The single largest cost considered by BRAC I in its evaluation of closing JPG was the cost to construct new facilities at Yuma Proving Ground, Arizona to accomnodate JPG's production testing mission. The Comission's report contained a military construction estimate of $39.5 million. This was based on data provided by the Department of the Army. In the course of our work, we have seen several other estimates for the same construction:

$21.8 million from MCA in an October 20, 1988 internal study by TECOM;

- $65.6 million from TECOM on October 26, 1988, which adds costs they believed should have been included in their prior $21.8 million estimate; $55.6 million the preliminary figure (November 17, 1988) used by the Commission; and

$98.9 million from a JPG engineer on April 27, 1989, based on his understanding of the requirements for facilities that Yuma may need to duplicate JPG's current peacetime mission.

- The Commission used the figure $39.5 million. (BRAC 1 Report, Dec 29, 1988

- Now that it is too late to make a difference, TECOM is using a figure of approximately $82 million that will be required to build facilities at Yuma. B. Cleanup of the Environment (GAO June 1, 1989) Like the hazardous waste situation, BRAC I did not include the cost of cleaning up unexploded ordnance at JPG as a cost for closing the installation. At this point in our review, we have identified three estimates of what it may cost to perform different levels of cleanup at JPG. As was emphasized by Toxic and Hazardous Material Agency official, these numbers should be regarded as rough estimates: .

$57 million--from the Toxic and Hazardous Materials Agency for cleanup of 36 SMU's;

, -4- I / 5550 million--from a consultant hired by the State of Indiana, using cost estimates contained in DOD reports and consisting of a cleanup of hazardous waste as well as subsurface (down to 3 feet) cleanup of ordnance on 8,600 acres and a surface cleanup of ordnance on 43,100 acres; and 52.8, 53.7, or $5.0 billion--from JPG's Directorate of Engineering, Logistics, and Housing for subsurface cleanup of ordnance down to 3 feet, 6 feet, or 10 feet, respectively. C. Value of Land of JPG (GAD June 1, 1989) An official at the CORPS of Engineers Real Estate Division told us they developed an estimate of 525 million. He said they were given 2 days to provide the Commission land values of over 130 Army properties. The CORPS used values of land such as $2,000 per acre, $750 per acre, and $350 per acre. The Corps did not take into account factors that could affect the appraised value of the land such as unexploded ordnance. D. Illustration of Flawed Data and Miscalculations (BRAC I Papers) The following table is submitted to illustrate the flawed data submitted by TECOM to the Commission:

Savings One Time Cost Per Year Payback 20 Oct 88, S53M S3.5M 15 years 26 Oct 88, 595.8M S5.6M 17 years 09 Aug 89, S207M f2.2M 94 years The BRAC I Commission ran the flawed data thru the cost model three times, manipulating the data each time to calculate a payback period. Finally, to calculate a 6-year payback, an inflated land value of $25 million was used to offset closure costs. This is in violation of DDD STD 6055.9 which states that land cannot be sold to the public until it is is rendered safe. 29 Dec 88 - Commission's Final Figures 565M -25M (sell land) S41M (one time cost) 6.7 M 6.1 years Nov___ 89 - General Accountinp Office (Cost Payback Figures) Without Cleanup Costs 5234M 6.3M 38 years With Cleanup Costs 51.26 Billion 6.3M 200 years E. DO0 Ordnance Cleanup Estimates

-5- Mar 89, S30M cleanup for unrestricted use of all 56,000 acres. Dec 89, SlOM cleanup of 3,000 acres in the administrative area, abandon impact areas until funding & technology are available for cleanup. 111. WHO IS TO BLAME? .LI Just about everybody! The PLANS office of TECOM explains it this way: A. Memo dated 27 Oct 88: To: Mr. R. Jameson, AMCMP-0 (Army Materiel Command) From: George Schroeter, Chief, PA&E, TECOM. ...Cost estimate provided to AMC on 20 Oct 88 to meet imnediate response requirement was based upon cursory examination of previous studies and identified one-time costs of S53M and annual savings of S3.5M. Re-examination by DEH&IL identified areas that were not properly considered. Revised cost estimate shows S95.8M one-time cost and annual savings of 55.6M. Information Paper attached sumnarizes pertinent facts.. . . B. Memo dated 18 Apr 89: (In repsonse to a request for information by GAO) To: CDR, JPG From: George Schroeter, Chief, PA&E Office ...Based on prior experience with base closure studies on JPG and internal updates of such studies, TECOM took a proactive position during deliberations by the Base Closure and Realignment Comnission. Input was generated internal- ly at HQ TECOM to scope costs on potential closure of JPG and this information was provided to HQ AMC for their utilization as required. Information is provided as enclosure l.... C . DO0 6055.9 STD Cleanup from unexploded ordnance was totally ignored: "To turn land over to non WD it must be rendered innocuous. Rendered innocuous--reasonable to assume property not contaminated with live ammo or explosives to an extent that constitutes unacceptable risk to public".

IV. UNREALISTIC LETTERS FROM THE PENTAGON

A. Date: Mar 23, 1989 From: Assistant Secretary of Defense To: Honorable Lee H. Hamilton ...Environmental costs were not used in determining the payback period. An environmental survey will be conducted to determine actual cleanup costs associated with the ordnance problem. Based on knowledge of cleanup costs at similar installations, the cleanup costs for unrestricted land use is estimated to be in the order of S3OM ... Signed By: Jack Katzen

-6- B. Date: August 23, 1989 From: Assistant Secretary of Defense To: Honorable Lee H. Hamilton ...The initial $30 million estimate for unrestricted land use is inaccurate. Final cleanup costs will depend on many factors that will not be available until the detailed studies are completed. The Department is comitted to providing adequate protection for human health and the environment and helping revitalize Jefferson Proving Ground to the extent we can within the funding available .... Signed by: Jack Katzen C. Date: December 1, 1989 From: The Office of the Assistant Secretary of Defense To: Mr. Michael S. Moore, JPG Survival Committee ...The Department of the Army is currently preparing an enhanced preliminary assessment at Jefferson Proving Ground in accordance with the Comprehen- sive Environmental Response Compensation and Liability Act (CERCLA)/Superfund Amendment and Reauthorization Act (SARA). Additionally. the Army plans to spend $10 million for cleanup of cantonment area. Following this, they plan to isolate the remaining ordnance contaminated sections until funding and technology are available to complete cleanup.. . . Signed by Frank Savat, Act- ing Director, Base Closul(e and Utilization COMMENT. The CORPS of Engineers, Louisville; Army Materiel Command, Washing- ton, OC; and TECOM, Aberdeen, MD funneled this flawed cost data to the Penta- gon. The Pentagon just repeated the information without any verification. Is there any accountability in Government service? Do we continue to make the residents of Southern Indiana suffer because inadequate or sloppy analysis on the part of civil servants? I THINK NOT. A letter from Susan Livingstone, Assistant Secretary of the Army to Mayor Morris Wooden contains a spread sheet from the COBRA Computer Program used to close bases. The spread sheet shows that using a total cost of $96.5 million to close JPG it would take 24 years to break even. The 96.5 million is much lower than the figured used by TECOM now. If we were to use the cost used by the Army now, the figure would be $136 million with a savings of $3 million per year which would give a payback of 45 years.

A. How is the Army going to reconcile the fact that Public Law 100-526 gave the Secretary of Defense the authority to sell the land of a base that is closed yet comply with DOD Standard 6055.9 which states that the land must be @ rendered safe prior to sale to the public?

-7- fires depleted uranium rounds. The agreement is that when testing stops the Army must imnediately cleanup 1,200 acres at a predicted cost of 514 million. How is this "caretaker status" going to comply with this signed agreement with the NRC?

C. The Madison Courier carried an article on Saturday, June 22, 1991 which is I included as Exhibit 1 titled: "Environmental Laws Hamper Base Sales". The crux of this article is that public law states that an entire base must be cleaned up before any parcel of it is sold. How can the Army pick and choose certain areas to study for cleanup under the National Environmental Police (NEPA) of 1969. Bases cannot be closed until an Environmental Impact State- ment is completed! The entire base must be considered. The Army can't pick and choose sites within the base to cleanup. we feel that this subverts the spirit of the law.

D. The Yuma newspaper has an article in it stating that the Mayor is urging residents of Yuma to conserve water. What is the effect of moving 200 more families to an area that is already strapped for water?

These questions and my other comnents need to be addressed in the completed Environmental Impact Statement.

THANK YOU.

-8- INDIANA DEPARTMENT OF NATURAL RESOURCES PATRICK R. RALSTON. DIRECTOR

I iiv~l;ii ol Outdoor Recreation

,ltl,l W Wn~lurqloriSI , I?m 271 Irl:li<111~1[~olii. lndiano 46704 (1i :23;j 4010 July 3, 1991

u.S. Amy Corps of ErqineeKS Lnu isv il le District ATI”: Mr. Jim Baker, CEORL-A)-R P.0. BOX 59 Louisville, KY 40201-0059

RE: DNR #4264 - Draft Environmental Impact Statement (DEIS): Closure of Jefferson Proving Ground; JeEfersm, Jennings, and Ripley counties

LXdr Ezr. Baker:

The Indiana Department of Natural Resources has reviewed the above refer- encd DEIS and offers the following ccmnents for your informaticn.

?he Jefferson Proving Ground (JFG) aontains a rich diversity of fish, wildlife, botanical, and other natural resources. Under current management practices, these resources have been available to the people of Indiana, subject to U.S. Amy restrictions. Regardless of any decision to retain or close JFG, our agency believes that these resources and the recreational benefits they provide should remain available to the public.

Wc are aware of the impact that JFG has on the area’s econany. If the final (kcision regarding closure involves deactivation of military management and pres- (.’we, howver, consideration should be given for public ownership of all OK part of JPG. We wuld recanned that the U.S. Any reclaim the property to its original &lands and associated fields. Public omership and use should include tmth consumptive and nonconsunptive recreational uses of the property’s natural 1 wsources.

Wc appreciate this oprtunity to be of service. If we can be of further dssistance, please do not hesitate to contact m.

Patrick R. Rslston, Director Department of Natural Resources PHH:SIIJ

cc: IL)M, Division of Water Wnagenent, Indianaplis, IN U.S. EPA, Region 5, Aquatic ReEources Secticn, Chicaw, IL U.S. Fish and Wildlife Service, Blmiryton, IN

“EQUAL OPPORTUNITY EMPLOYER’’ a 14. JOHN ONEIL COMMENTS RECEIVED JUNE 12, 1991

COMMENTS ARE PARAPHRASED FROM A MARKED-UP COPY OF THE DEIS AND ARE LOCATED IN APPENDIX L DEPARTMENTS OF THE ARMY AND THE AIR FORC NATKmAL GUARD BUREAU ANDREWS AIR FORCE BASE DC ?of)l-WM c i 'f. 1, ILUN i991 IrR"10 m~orNCB f DEVA

Iuslrcl Comments on DEIS for the Closure of Jefferson Proving Ground. Indiana and Realignment to Yuma Proving Ground, Arizona

U.S. Army Corps of Engineer District. Louisville ATTN: CEORL-PD-R (Hr. Jim Baker) P.O. Box 59 Louisville, KY 40201-0059

1. Upon reviev of the DEIS, it was apparent that the document calls for the complete removal of all military activities from Jefferson Proving Ground (JPC) including the National Guard Bureau (NGB) Air to Ground Weapons Range. This is not the desire of the NGB. We would, therefore, request you incorporate the retention of the weapons range and its personnel in any reuse alternative pursued.

2. As you are avare, air to ground weapons ranges are a valuable asset and tool in training OOD air crews. JPG's proximate location to numerous NCB, AFRES and other military units makes the range irreplaceable.

3. We would appreciate the opportunity to discuss our request with you at the earliest possible date. Please contact my POC. Mr. A1 Loftin at 301-981-8137, with your response to our request. Thank you for your cooperation.

J. WENDELL KIER. Chief 4Airspace Management Branch / wvv -_l. Louisville Corps of Engineers -mike Moore Col David Peixotto 242 Crestwood Louisville, Ky . Madison, Indiana 47250 Reference: Testimony Meeting June 26, 1991 June 24. 1991, Nadlson Ir. t

This Draft Enviroment Impact Statement must address the following questions: A. How is the Army going to reconcile the fact that Public Law 100-526 gave the Secretary of Defense the authority to sell the land of a base that is closed yet comply with DOD Standard 6055.9 which states that the land must be rendered safe prior to sale to the public? B. How does tt:? term "long-term caretaker status" comply with the base closure law? Under a license from the Nuclear Regulatory Commission, JPG test fires depleted uranium rounds. The agreement is that when testing stops the Army must immediately cleanup 1,200 acres at a predicted cost of $14 million. How is this "caretaker status" going to comply with this signed agreement with the NRC? C. The Madison Courier carried an article on Saturday, June 22, 1991 which is included as Exhibit 1 titled: "Environmental Laws Hamper Base Sales". The crux of this article is that public law states that an entire base must be cleaned up before any parcel of it is sold. How can the Army pick and choose certain areas to study for cleanup under the National Environmental Policy Act (NEPA) of 1969. Bases cannot be closed until an Environmental Impact State- ment is completed! The entire base must be considered. The Army can't pick and choose sites within the base to cleanup. we feel that this subverts the spirit of the law. 0. The Yuma newspaper has an article in it stating that the Mayor is urging residents of Yuma to conserve water. What is the effect of moving 200 more families to an area that is already strapped for water?

E. The meeting to receive commentson the graft CIS brouebt a surprise. We did not expect the Corps to State that This EIS would only cover the period from noe to closure. Then another EIS would be performed after the Base Was closed. Is there any other Base , landfill or cleanup site that has been cleaned up with two EIS? Can you explain the how the decision to conduct the two EIS was arrived at and who made the decision?

Sincerely yours, d- Mike Moore AlOCHEM NORTH AMERICA IN(. 7116 Highland Avenw C.irrolllon KY 41008

TI.1 l',fl21 /3? .IJ! !

June 27,1991 James M. Baker U.S. Army Engineer District P.O. Box 59 Louisville, Ky 40201-0059 re: DEIS Jefferson Proving Ground Dear Sir: As a taxpayer, resident of Jefferson Co. Ind., and chemical engineer I think it a serious matter that the Army consider full clean-up of the Jefferson Proving Ground site. Chemical industry has been burdened with RCRA clean-up at its sites and it is only just that the Government act as the government expects its people to act in these matters. Logistics, money, and time will dictate the course which is chosen but conscience should be your guide. We all make mistakes but perpetuating them is unconscionable. Residents of the area have supported and put up with the round the clock noise and vibration of the activities there and deserve peace of mind and quiet after its gone. Worry about contamination or other unforeseen events or emergencies after activity ceases is not closing the Proving Grounds

/J James A. Bozin Technical Manager MADISON INDUSTRIRL DEVELOPMENT CORP.

U.S. Army Corps of Engineer District, Louisville ATTN: CEORL-PD-R (Mr. Jim Baker) P.O. Box 59 Louisville, Kentucky 40201-0059 Dear Sir: I am in receipt of the Draft Environmental Impact Statement (EX) for the Closure of Jefferson Proving Ground, Indiana and realignment of mission to Yuma Proving Ground, Arizona. I would like to make some brief comments pertaining to the EIS. In the EIS, the statement is made that "environmental impacts are considered to be primarily beneficial due to the cessation of testing ordnance and disposal'of hazardous materials at JPG. No additional environmental Contamination will result due to the closure of JPG. However, the extent and level of existing contamination are unknown." It is also stated that "the JPG analysis focuses upon closure and the commitment of property to caretaker status ... This EIS does not address specific actions or impacts associated with potential remediation activities at JPG. 'I I think that the lack of knowledge about existing contamination is a major omission in assessing the environmental effects of the closure of JPG. Because we do not know how contaminated JPG is, we cannot know if cessation of testing ordnance will result in the cessation of additional environmental contamination. We also cannot know what remediation activities are appropriate. But by not knowing what types of remediation are required, we cannot know if remediation would have a more adverse effect on the environment than continuing to operate JPG as an ordnance testing facility. This does not even,consider a comparison between the anticipated cost savings and the actual expenditures which may result. In summation, the lack of complete and accurate information for the Draft EIS only compounds the problem caused @' by the same lack of information on which the Base Realignment and Closure Commission based its decision. I appreciate the opportunity to submit my comments on the Draft EIS and 1 look forward to receiving the Final EIS. Thank you. Sincerely, fl,fL.. &AL MARIE-CHRISTINE hPENCE Executive Director

101 w. =DUX MAIN STREET . MADISON, INDIANA 17250 To: James Baker

U.S. Army Engineer District - Louisville Corps of Engineers P.O. Box 59 Louisville. KY 40201-0059

Attn: CEORL - PA

Re: Draft EIS for Jefferson Proving Ground

Dear Mr. Baker:

was planned by the Army. The RI/FS for the 3,000 acre site will not address public concerns on the potential environmental hazards that may exist at JPG. I would like to @ offer the attached comments as public comment to the draft EIS. In my comments I believe there is a way by which the concerns regarding the range north of the firing line can be

all comments received by the COE in regard to- the draft EIS as well as the final EIS be submitted.

Sincerely,

Mohan N. Pundari, P.E.

ENVIRONMENTAL SYSTEMS & SERVICES, INC A Subsidiary of 2605 Enterprise Road East. Suile 104, Clearwater. Florida 34619 Valentcc Inicrnauonal Corporanon

Telephone (813) 726-0966 Fax (813) 725-1728 (hrolrt, 7hhrrw-h Irzlnu Written Comments on Jefferson Provine Ground Draft Environmental ImDact Statement

During the public meeting for the Draft Environmental Impact Statement for Jefferson Proving Ground (JPG), many citizens and political representatives were concerned about the Army's plans for restoration of the installation. The Army's proposal to place it into a "caretaker" status does not seem to meet the law's requirement that the installation be closed, restored and sold for approximately $25 million. Throughout the evening it was clear that the primary environmental concern not being addressed is the UXO and other contamination that may exist north of the firing line. The EIS does propose a comprehensive RI/FS (Remedial Investigation/Feasibility Study) for the area south of the firing line consisting of approximately 3,000 acres of the 55,264 acres that comprise Jefferson Proving Ground. During the meeting it was stated that the draft EIS was to only address the issues regarding closure and another EIS will address the issues regarding post-closure. If this is the reason why an RI/FS is not required for the range then it can be extrapolated that the RI/FS for the 3,000 acres is unnecessary at this time too, and if true then the Army should wait for the post-closure EIS for implementation of any RI/FS work. Clearly an investigation needs to be performed for all of JPG, as part of the closure action.

In listening to the comments presented at the public meeting, I believe that what will satisfy public concerns is a draft plan for performing a PA/SI (Preliminary Assessment/Site Investigation) for the range.

Range lnvestivation and Hazard Assessment

The range is contaminated with a large amount of unexploded ordnance (UXO) and potentially the chemicals and heavy metals which make up an ordnance system. Potential contaminants may include items listed in Table 1.

1of5 5 2,4,6 - Trinitrotoluene 2,4 - Dinitrotoluene (2.4 - DNT) 2.6 - Dinitrotoluene (2.6 - DNT) 1.3.5 - Trinitrobenzene Nitrobenzene Cyclotrimethylenetrinitrarnine (RDX) Cyclotramethylenetetranitramine (HMX) Hexahydro- 1(N)-acetyl-3,5-dinitro- 1,3,5-triazine (TAX) Octahydro-l(N)-acetyl-3,5,7-trinitro-1,3.5,7-tetrazocine (SEX) Dimethylnitrosamine (DMNA) 2.4.6 - Trinitrophenylrnethylnitramine (Tetryl) Pen taerythri to1 terani trate (PETN) Triarninoguanidine nitrate (TAGN) Nitroguanidine (NQ) Diphenylamine (DPA) p-Nitrodiphenylarnine (4-NPDA) Aniline N.N - Dimethylaniline Trichloroanaline Metals (such as nickel, silver, mercury, and lead) Nitrate/Nitrite Sulfate/Sulfite Cyanide Chlorinated Hydrocarbons Itad Azide Ixad styphnate I-Gunnyl-4-nitrosoaminoguanyl tetrazene (Tetracene) Ammonium Picrate; Picric and Picramic Acids (Yellow-D) Polypropyleneglycoldinitrate (Otto Fuel) (PGDN)

2 of 5 Problem:

How can identification of the potential contaminants and extent of UXO be determined in an economical manner?

Potential Solution:

It has been reported that most unexploded rounds are within 5-6 feet of the surface. These rounds may be detected through the application of multi-spectral sensor systems. Detection of subsurface anomalies is performed by:

- Establishing projectile size, material, and chemistry.

- Determining soil & terrain conditions, climate, ground cover, etc.

* Selecting spectral bands to be analyzed to uniquely determine the target.

Determine spatial resolution requirements.

- Acquire and process imagery taken by aerial cameras and sensors flown over the site.

- Identify subsurface object(,) location, size, concentration and condition (extent of corrosion on rounds)

Multi-Spectral Sensor Systems have been proven to detect subsurface objects/features as demonstrated by the following examples:

Detected 3” metal pipeline buried 42” ? 6 from 10,000 to 20,000 feet altitude (Alberta Remote Sensing Centre 1979)

- Detected man-made paths created 1,OOO years ago and covered by five feet of volcanic ash from 1,OOO ft. altitude in Costa Rica. Paths were one foot wide. (NASA 1985)

I believe that the multi-spectral sensor system may have sufficient resolution and sensitivity 10 identify UXO or at least major areas of UXO. Once the objects are identified, we can characterize the number and type of projectiles at various sites on post. For each type of round. we can develop a hazard analysis of the chemicals and heavy metals expected to be released into the environment by researching the Technical Data Package (TDP) for that roiinil.

’l‘he knowledge of projectile material composition and soil characteristics can also be IiLilized to project the corrosion rate of the projectiles and predict at what rate potential releases into the soils and groundwater will occur. This data on location, type,

3 of 5 concentrations, and age of projectiles can be compiled to predict areas where "hot spots" for contamination are likely to occur or exist today.

The goal of the Army is to protect the surrounding land and water resources from contamination leaving JPG property and into the environment that may result in health risks to the population around the installation. When contamination does go offsite, the Army will protect the public from health risks. For example, at the U.S. Army's Picatinny Arsenal Facility, RDX contamination has been detected in the drinking water supplies of the surrounding population and the Army is providing bottled water to those affected. The Army would also likely initiate clean-up of "hot spots" before the contamination is dispersed and require restoration of a large area. Identifying and cleaning up "hot spots" quickly will lower the cost of environmental compliance to the Army and to the American taxpayer.

I believe that the preferred method of treating the site is to use in-situ treatments that require minimal disturbance of buried UXO and other energetic materials. The preferred method for treatment will probable be a biotreatment methodology. Although biotreatment is an effective and viable method worthy of investigation, it will .take significant time to identify and optimize an in-situ ecosystem for the site specific conditions existing at JPG. Biotreatment can be supplemented with other techniques to enhance the release of energetic materials from the projectiles into the environment where the optimized ecosystem can attack and render their hazardous contaminants harmless.

A plan should be developed for the research and development of in-situ treatments and processes to minimize health, safety, and environmental risks at the lowest practical cost. It will be cost prohibitive to excavate all UXO and other contaminants from the range. In- situ treatments are the area where the attention must be focused to remediate the site at the lowest cost to the taxpayer. From the Army's research and development program on in-situ treatments, the most promising treatment methods should be selected for demonstration and validation at JPG. Should no viable treatment be demonstrated then other alternatives to isolate and prevent contaminants from being transported off-site must be evaluated and demonstrated. If an in-situ treatment or other alternative has shown promise to effectively protect public health, safety and environment, the Army should implement the treatment in a timely manner.

A comprehensive sampling and analysis plan should be implemented to verify that the contamination hazard has been eliminated. During treatment the rate of degradation must be monitored to improve process variables and increase the efficiency of treatments. After all clean-ups and decontamination of the site has occurred, a plan to monitor the site must he established. If the Army selects in-situ treatment systems, it can be difficult to conclusively determine whether all of the contamination has been effectively treated. A long term monitoring program to assure and maintain the performance of the clean-up activities should be implemented as part of the remediation plan.

~ The plan outlined above, I believe, is a practical, low cost, realistic methodology that will Army retains JPC in a caretaker status, an investigation into the extent of range contamination and potential health, safety, and environmental risks should be conducted as is planned for the 3.000 acre area as identified in the draft EIS. The first step is to identify @ the extent and quantity of contamination at JPG. What will be done about any contamination that is found must be evaluated based upon the risk assessments developed as part of the Army’s restoration plan for JPG. C- C- DAN COATS ARMED SERVICES INDW - LABOR AND HUMAN RESOURCES I 'United States Senate WASHINGTON, DC 206 10

June 27, 1991

Colonel David E. Peixotto, District Engineer Louisville District, Corps of Engineers P.O. Box 59 Louisville, Kentucky 40201-0059

Dear Colonel Peixotto: Enclosed for your information you will find copies of several photographs from Jefferson Proving Ground. These photographs show various examples of unexploded ordinance in the area north of the base firing.

As I indicated in my testimony on the Draft environmental impact statement at the June 24, 1991 public meeting held at Madison High School, I believe several of these photographs should be included in the final EIS in order to alert the public to the very real risks associated with this site.

I appreciate your consideration of this request.

Dan Coats United States Senator

DC/1 r

. July 5, 1991

Mr. Jim Baker U.S. Army Corps Of Engineer District, Louisville e.0. BOX 59 Louisville, KY 40201-0059 Dear Mr. Baker: This is a letter of comment on the EIS for the closure of Jefferson Proving Ground, Indiana. I am an Associate Professor of Biology at Hanover College. Hanover College is located in Jefferson College near JPG. My field of research is the ecology of amphibians and reptiles, and I have spent a considerable amount of time at JPG involved in research and teaching activities. L was consulted concerning amphibians and reptiles in the preparation of the EIS. My comments here are directed toward the natural resources of JPG with which I have some familiarity.

From the perspective of natural resources the EIS is an incomplete and inadequate document. The EIS repeatedly states that no systematic botantical or zoological survey of the JPG property has ever been done. Without this baseline information all conclusions are based largely on guesswork and partial information and must be viewed with caution. The bottom line is that we do not know what the natural resources of the JPG prperty really are, and the EIS is therefore unacceptable. I think that the writers of the natural resource sections did the best they could with inadequate information. Let me be more specific regarding amphibians and reptiles -- my area of expertise. The strategy of the EIS is to list species that could potentially occur in the area based on published distribution maps and consultation. Without actual survey information these lists are of very limited value and are in fact misleading. For example the report states that there is a good possibility that the Four-toed Salamander and Northern Red Salamander occur on the property. Base on published distribution map information this Is true. However the microhabitat requirements of these species are such that it is extremely unlikelv that they will be found at JPG. I could give other examples, but I think I have made my point. I repeat: The E13 is a superficial and inadequate document because an adequate survey of the botanical and zoological resources at JPG has never been conducted. I do not see how sound environmental judgements regarding future activities at JPG can be made based on this document. The EIS is simply a statement of ignorance. .

Assbciate Professor of Biology Canters tor Disease Cotitro~ Atlanta GA 30333 June 28. 1991

U.S. Army Corps of Engineer District, Louisville ATTN: CEORL-PD-R (Mr. Jim Baker) P.O. Box 59 Louisville., K:+r.tuckjr 43201-0053

Dear Mr. Baker:

We have completed our review of the Draft Environmental Impact Statement (DEIS) for the Closure of Jefferson Proving Ground (JPG). Indiana and Realignment of Mission to Yuma Proving Ground (YPG), Arizona. We are responding on behalf of the U.S. Public Health Service.

We have reviewed the DEIS for potential adverse impacts on human health, and we believe potential adverse impacts have been adequately addressed; however, we note that compliance with various environmental statutes are ongoing. Although the DEIS does not address specifications associated with future potential remediation activities at JPG, we note that the Army acknowledges that requirements concerning environmental compliance will be met prior to the disposition of property. We understand that a separate analysis of reuse alternatives will be performed in accordance with the National Environmental Policy Act (NEPA) in an effort to ensure the health and safety of potential users of the land.

It is stated that surface waters may be affected by the contribution of existing pollutants from soils which already have been contaminated. Groundwater contamination to off-site users is also possible with the closest Fo'encZal sirurca beins Gate 19 iandr';ll. A5 notc3. Lire pert usags; did disposal of hazardous materials may have a long-term impact in which the level and extent is currently unknown. Therefore, mitigation plans for minimizing these potential impacts should include, among other identified measures, the erosion and sedimentation plan indicated as needed in the DEIS, and continuation of the monitoring plan to detect possible migration of contaminates in the future.

Several corrections are needed in the list of addresses receiving copies of the DEIS for future reference. The Department of Health, Education and Welfare, listed in two National addresses and one regional address, has been renamed the Department of Health and Human Services for a number of years. Mr. Charles Custard should be deleted, and the address for the Centers for Disease Control should be revised to reflect the address on this letter. Page 2 - Mr. Baker

Thank you for the opportunity to review and comment on this document. Please insure that we are included on your mailing list to receive a copy of the Final EIS. and future EIS's which may indicate potential public health impact and are developed under NEPA.

Sincerely yours,

Keineth W. Holt, M.S.E.H. Special Programs Group (F29) Center for Environmental Health oiid Injury Control Route 7, Box 132 Madison, Indiana 47250 2 July 1991

U.S. Army Engineer District, Louisville Attn: James M. Baker (CEORL-PD-R) P.O. Box 59 Louisville, KY 40201-0059

Dear Mr. Baker,

I would like to present some written comments on the closure of Jefferson Proving Ground and the Draft Environmental Impact Study which has been done. First, I wish, in no unequivocal terms, to state that I am displeased with the closing of JPG. Jefferson Proving Ground had large quantities of very valuable assets for this country. It is an excellent proving ground for the testing of small arms, mortars, field artillery, and tank guns and ammunition. Within its area of purview, it could test items on a more efficient and faster turnaround basis than other proving grounds. Over and above the facilities, Jefferson Proving Ground's greatest asset is its people. There is a great deal of expertise at Jefferson Proving Ground which took many, many years of experience to build.

I do understand that times change. If the decision is made that the world situation is changing, and that Jefferson Proving Ground is no longer necessary for the defense of our country, I may not agree with the decision, but I must abide by it.

Therein lie my feelings about the proposed uses for Jefferson Proving Ground. It has been said that the worst possible solution for JPG would be to fence it off and leave it as a wildlife refuge. I vigorously disagree. This is shortsighted in the historical context, shortsighted in financial terms, and extremely shortsighted in terms of possible future service of Jefferson Proving Ground to our country.

Contamination of ground by unexploded ordnance is a contamination which, though hazardous, is not active or offensive as is contamination by PCBs, nerve gas, or other sorts of toxins. The unexploded ordnance will not release contaminants into the ground water supply. Further, it will not release clouds of hazardous gases. Even if a forest fire were to sweep the area there would be no danger outside the boundaries of Jefferson Proving Ground.

To this day, there are literally millions and millions of acres of land which are similarly contaminated. There are large Page 2

tracts of the North African desert which are posted as off limits to man due to the millions of land mines which were laid during world War I1 and which were never properly recorded. In France, there are millions of acres of land which are still off limits as a result of the great artillery duels of World War I. This land will never be reclaimed due to the hundreds of millions of artillery shells which are buried within the earth. On yet still untold millions of acres of France, the farmers go about their daily chores and routinely plow up unexploded ordnance. In all the countries of Europe, bomb disposal squads are maintained in a constant state of readiness and literally work seven days a week in disposing of the unexploded refuse of World War 11. Though the war was over 45 years ago1 the low threat of unexploded ordinance to which the people of Europe have become adapted. Farmers in England regularly unearth bombs and building renovation crews in London and other cities regularly unearth the ordnance. This is true throughout Holland and particularly throughout Germany.

The Europeans, where population density is much higher than the United States and land values are high, have not been able to perfectly clean out the ground and they simply fence the ground off or live with the low level of threat.

The same situation exists at Jefferson Proving Ground. However, I would like to think Jefferson Proving Ground's contamination is a monument to the grace of God and the sturdiness of the American people. What a magnificent thing that the shells that we had to test are restricted to a small patch of ground. What a great miracle that the shells and bombs of our enemies never fell upon this land. It is a miracle that our farmers will never have to worry about unearthing unexploded ordnance. It is a miracle that our construction crews will never have to wonder if, the next time they strike a wall with a crowbar, the bar will go through and detonate a piece of unexploded ordnance.

Every nation pays a price for war. Even those who win still pay the price. We not only pay the price in terms of lives lost, dollars spent, and resources squandered, we also pay the price in land which is forever unusable. In the historical context, we have gotten off easy. We have paid a small price. I see no problem whatsoever, in historical terms, of leaving Jefferson Proving Ground permanently fenced off.

From there, one must consider the economics of clean-up at Jefferson Proving Ground. I am pretty familiar with the unexploded ordnance at Jefferson Proving Ground and the methods of cleaning up an area contaminated by such ordnance. There are areas at Jefferson Proving Ground which are heavily contaminated with both unexploded and inert ordnance. These shells have easily gone as deep as 20 and 30 feet into the ground. Further, Page 3

before the shells decelerate to a halt, they can easily burrow through the earth and go outside the approved impact areas. Clean-up of such an area is both massively difficult and risky. A shell buried 20 feet under the surface of the earth represents relatively little danger. However, to dig down after that shell is an entirely different matter indeed. It either must be done by hand, scraping off fractions of an inch of earth at a time, or it must be done by mass machinery with the consequent increased danger of detonation upon striking the ordnance. Further, the earth must be sifted in order to insure that all ordnance is found. From there, items must be detonated one at a time as they are discovered. All told, it is an incredibly difficult, manpower consuming, and time consuming task.

In Europe, where the land is of much greater value per acre than in the United States, they have given up in their attempts to decontaminate many patches of ground. This is particularly true in France and in some of the training grounds in Germany. Compared to the value of the land, the costs of clean-up are simply not justifiable. The unexploded ordnance is not a threat outside the fences of Jefferson Proving Ground. An active effort to clean it up and restore the ground to some kind of perfectly safe civilian usage is simply not worthwhile. The costs of this would be astronomical. This is not to mention the fact that surety and safety cannot be guaranteed. Even if millions of cubic yards of earth are turned over and sifted, how can we be sure that every shell has been found?

Lastly, we must consider the future. History shows that the creation of Jefferson Proving Ground was accompanied by a great deal of suffering on the part of many land owners. In any place, at any time, it is extremely difficult to remove the human population and set aside land for government uses. In the event of a future war (and one will surely come someday), the value of Jefferson Proving Ground cannot be underestimated. It is true that the facilities (buildings, roads, etc.) will probably deteriorate. Further, it is certainly true that the advance of technology will render many of the facilities at Jefferson Proving Ground outdated at best. This does not mandate against a total dismantling of Jefferson Proving Ground. The fact that the land is set aside and already contaminated and surveyed may be of great future value. Instead of a six-month or year long process attempting to set aside land (and all of the attendant legal battles) a patch of land will already be in existence. In a matter of weeks, OK at best a few months, teinporary building can be in place and new instrumentation can be installed such that Jefferson Proving Ground could easily test the small arms, mortars, field artillery, and tank cannon which it is so well suited to. In a future conflict, where reaction times will surely be short, this land may represent an inestimably vsluable asset to our nation. Page 4

It is unfortunate that the decision has been made to close Jefferson Proving Ground. I disagree with that. However, if the closure must be done, then I fully support fencing off Jefferson Proving Ground and letting it lie fallow. The Contamination is benign. From the economic standpoint and the historic and future value standpoint, it is best not to disturb it but to let it lie fallow.

Sincerely yours,

Arthur 8. Alphin

ABA/eb OFFICE OF TEE GOVERNOR INDIANAPOLIS, INDIANA 4680~.a797

EVAN BAVH GOVERNOR July 5, 1991

P.O. BOX-59 Louisville, Kentucky 40201-0059 Dear Mr. Baker: I am enclosing with this letter the comments of the Indiana Department of Environmental Management (IDEM) on the Environmental Impact Statement (EIS) you have proposed on Jefferson Proving Ground. I am profoundly disappointed by the apparent lack of concern this EIS shows for Indiana's environment and the safety of its citizens. I do not need to reiterate all of the concerns expressed by IDEM, but I want to be clear that the people of Indiana will not tolerate the ever-increasing environmental dangers and the real public safety risks that abandonment of JPG without adequate cleanup represents. If the EIS is accepted as written, the Army will be setting the stage for disasters of the kind that befell the two children who were killed in an explosion at the Tierransanta Range in San Diego, California. That tragedy arose when concern for public safety was disregarded during a base closure. acceptance o? this EIS is to accept the right of the Department of Defense to degrade the environment without acknowledging responsibility for actions taken under its stewardship. I hope you will seriously consider these concerns and develop a plan which is environmentally sound and effectively protects public safety. Sincerely,

-+-Evan Bayh EB/tlb

PRlKlFD BY EMPLOYEES OF ?HE STAE OF I"A ON RECYCLED PAPER INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

105 South Meridian Street P.O. Box 6015 Indianapolis 46206.6015 Telephone 317/232-8603

Mr. James H. Baker U.S. Army Corps of Engineers P.O. Box 59 Louisville, Kentucky 40201-0059

Dear Mr. Baker:

Staff of the Indiana Department of Environmental Management have reviewed the Draft Environmental Impact Statement for Closure of Jefferson Proving Ground Indiana and Reallpent to Yuna Proving Ground Arizona. The following conrments are directed solely at sections of the Environmental Impact Statement (EIS) pertaining to Jefferson Proving Ground (JPG).

It is apparent from the EIS that the Army strongly favors the commitment of JPG to caretaker status into the distant future. This position is extremely shortsighted and poses great potential for harm to human health and the envirornnent. The EIS proposal to place the area north of the firing line in caretaker status is also contradictory to the commitment in the EIS that the DOD intends to close the facility in accordance with RCRA regulations. The DOD decision to proceed with closure for a few of the RCRA regulated solid waste management udts in the area south of the cantonment area ignores the very serious problems north of the firing line. The failure to address the units identified in 0 the March 1990 Enhanced Preliminary Assessment Report violate. Federal and State closure laws under RCRA and State Solid Waste Rules. Simply providing security for the widespread contamination that exists north of the firing line does not constitute proper or legal closure of the waste management units on the facility and does not therefore support the contention -de in the EIS.

Of major concern to this agency is the lack of plans to address unexploded ordnance (UXO) downrange from the cantonment area. The EIS states that UXO can be found virtually everywhere on JPG. Given this admission and the death and injury experienced at other closed facilities, there is M reason to believe any serious consideration has been given to public safety. There is also no indication of . consideration being given to the potential affects of bioaccuulation in game species resulting from contact with hazardous constituents from UXO.

The EIS does mention plans to conduct a natural resource inventory and appears to recognize the value of the natural resources at JPG. However, plans for the protection of those resources are woefully I An Equal Opportunity Employer Mr. James M. Baker Page Two

inadequate. Of particular importance is the presence of a Great Blue Heron Rookery on the facility. The EIS fails to discuss any plans for the protection of this valuable resource.

Six stream corridors have been identified as,crossing the facility, each with a great degree of ecological diversity. The report states that there are suspected releases of contaminants to surface waters from cracked UXO, the Depleted Uranium Impact Area, red lead disposal areas, burn areas and the sulfur disposal area. However, this report does not contemplate the migration of contaminants from this facility via these stream corridors. A Remedial Investigation/Feasibility Study must be undertaken to study all six streams to determine the extent of contamination and evaluate the risks to human bealth and the environment on and off the facility.

While the stated intent of the EIS is to evaluate the environmental impacts of base closure, it is a far reaching assumption that the curtailment of activities at JPG Vi11 have no negative impacts on wildlife. The EIS lacks sufficient data and detail to adequately 8 evaluate any impacts. positive or negative, and certainly lacks any specific combitstent to fully address this vital concern.

It is our opinion that the EIS falls far short of adequately assessing the environmental impact of base closure. Many of IDEM'S comments and concerns expressed previously were either completely ignored or mentioned only in general terms. There remains a complete lack of pertinent site data which are essential to fully evaluate the impact of base closure and to develop viable future use plans for the facility. The WD indicates in the EIS that it has no plans to collect the data necessary to truly evaluate the extent of contamination or to remediate the most significantly contaminated portions of the facility. Indeed, while it states it intends to comply with RCRA closure rules. the projected closure action for the units north of the firing line indicates otherwise.

The IDEM believe8 this EIS is inadequate end incomplete and proposes I totally unacceptable base closure conditione. This statement is based upon the failure of the DOD to fully evaluate the environmental impact of base closure, the lack of commitment to conduct a comprehensive facility remedial investigation, the failure of the WDto evaluate or to consider the cleanup of the most highly contaminated portions of the facility, the lack of a realistic or thoughtful discussion of future land use options. and the unresponsiveness to previously provided IDEM concerns.

Thank you for the opportunity to comment on this Draft EIS. Please direct any responses to these comments to Ma. Corinne Wellish, Assistant commissioner, Office of Environmental Response.

Sincerelg ,-

&thy Kosser Commissioner Pacific Studies Center WBView StreQ Mounlain View, CA 94041 USA 415i969-1545:Fn4151%&1126 July 9,1991 James Baker, F’D-R U.S. Army Corps of Enginem Box 59 Louisville, KY 40201-0059

ordnance in the base’s range areas. Ordnance is cornpod of toxic substances, including white @ phosphorous, RDX, TNT, etc. In fact, scvdArmy ammunition plants are on the Superfund National

To adequately protect the environment at and around the Jeffcrson Roving Ground. it is important to do detailed projections about the toxic life of the explosives and their byproducts. to make an assessment of the likelihood that the chemicals will spread from their shells. and to dcvelop models of environmental dispersion. The risk of toxic contamination fmm uncxplodcd and explodcd ordnanct is not unique to the Jefferson Roving Ground, but this facility represents m of the most severc cases. If, in the come the type of study that I propose. it turns out that other. active proving grounds pose a similar environmental risk, then the Army should develop procedures to mitigate the environmental risk at thosc facilities as well. Perhaps the greatest long-term threat of toxic exposure at the Jefferson Proving Ground is from the ordnance in the impact areas. It would make a mockery of the environmental review pnxess 10 ignore that threat dybecause the Army cumntly has no plans to restore that massive piece of Ral estate.

sincerely. P

nny Siegel, . Chief Researcher, National Toxics Campaign Fund’s Military Toxics Network

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9 18/27/1991 Q8:88 FROM R SPRINGER TO 84046.367 162 F . I8 TO 1&27 1991 m:@i FROM R SPRINGER TRANSCRIPT OF A PUBLIC MEETING

HELD ON

24 JUNE 1991

THE MADISON HIGH SCHOOL AUDITORIUM MADISON, INDIANA

CONCERNING JEFFERSON PROVING GROUND BASE CLOSURE

U.S. ARMY ENGINEER DISTRICT, LOUISVILLE CORPS OF ENGINEERS CONTENTS

SECTIONS AND TITLE

I. INTRODUCTION INCLUDING PUBLIC NOTICE)

11. TRANSCRIPT OE PUBLIC HEARING

111. REGISTERED ATTENDANCE

IV. EXHIBITS I. INTRODUCTION (INCLUDING PUBLIC NOTICE)

. I. INTRODUCTION

A public meeting was held concerning Jefferson Proving Ground. The meeting was held to hear comments and answer questions concerning the Draft Environmental Impact Statement on the closure of the Proving Ground.

DATE : Monday, 24 June 1991

PLACE : Madison High School Auditorium Madison, Indiana

CONVENED: 7:30 p,m. EST ADJOURNED: 9:15 p.m. EST REGISTERED ATTENDANCE: 102

A review of this verbatim transcript will serve to assist the Corps of Engineers in preparation of the final Environmental Impact Statement.

All letters, statements, reports, and memoranda received in connection with this public meeting are on file in the Office of the District Engineer, Corps of Engineers, Louis- ville, Kentucky, and are available for public review. 11. TRANSCRIPT OF PUBLIC MEETING 1 11. TRANSCRIYT 2 3 COL PEIXOTTO: Thank you all for joining us tonight. It's great to have 4 you here. Good to see the turnout. It shows a lot of interest, and I 5 know this is a subject that is on the minds of the people that live in 6 the Nadison area, and particularly the people at Jefferson Proving 7 Ground--on your minds very often. 8 9 I'm Colonel Dave Peixotto. I'm the Commander of the Louisville District 10 of the Corps of Engineers. We provide engineering and environmental 11 support to military installations, including Jefferson Proving Ground. 12 We have been asked by the Army to prepare the environmental impact state- 13 ment for the closure of Jefferson Proving Ground. About two years ago, 14 we stood in this auditorium. How many of you were here two years ago at 15 the scoping meeting? (Several hands go up.) Very good. We received 16 from you your advice, your concerns, your recommendations, on what should 17 be included in the draft environmental impact statement. I told you 18 that as soon as we published the draft environmental impact statement 19 that we would be back for you to grade our paper and tell us how we've 20 done in assessing the impacts of closing Jefferson Proving Ground. And 21 here we are. 22 23 Now, those of you who raised your hand saying you were here two years 24 ago, you should have received a copy of the draft environmental impact 25 statement in the mail. Those of you who are here tonight but were not 26 here two years ago, and all of you for that matter, I hope you filled 27 out a registration card when you came in. By this, we know two things: 28 that you are interested in this subject and so we can keep you 29 informed. Those of you who were here two years ago filled out one 30 of these cards and received a copy of the draft environmental impact 31 statement. If you filled one out tonight, you will receive a copy of 32 the final environmental impact statement. Now, if you .haven't, 33 Mr. Schwann has one for you to fill out. So, please raise your hand 34 to make sure that you get one. 35 1 1’11 be conducting the meeting tonight, and I would like to introduce 2 the people up here helping me. First, is Mr. Bob Jameson of the U.S. 3 Army Materiel Command; Bob, would you raise your hand, please. This is 4 the major command that is responsible for the completion of the closure 5 action. Mr. Kauskik Joshi of the Army Toxic and Hazardous Materials 6 Agency. Ms. Kathy Martin of the Louisville District Corps of Engineers 7 Real Estate Division. Mr. Jim Baker from the Louisville District 8 Planning Division; Jim is the Project Manager for the environmental 9 impact statement. And Ms. Alyse Getty of Wapora, Inc., the contractor 10 that prepared the draft environmental impact statement. We have a 11 variety of support staff here with us to answer any technical questions 12 you might have. This meeting is being recorded and a transcript will be 13 prepared and become a part of the official record. 14 15 First, I would like to explain a few administrative points. As you 16 entered, you were asked to fill out the card, and we need you to do that 17 because it tells us who wants to make a statement. Now, that doesn’t 18 mean if you didn’t check “Yes, I want to make a statement’’ on your card, 19 that you can’t make a statement. But it does means that if you did, you 20 will have the first opportunity to do so. We’ll give everybody a chance 21 to speak tonight, to make a statement, to ask questions. Our purpose is 22 to make sure that when we get to the final environmental impact statement 23 on closure that it is complete and that the Army can make a decision with 24 full information at its hands. If you make a presentation, please limit 25 it to a reasonable amount of time. We’ll spend as much time 8s we need 26 to here tonight so that everyone has a chance to speak or ask questions. 27 28 I’d like to give you some background on the Secretary of Defense’s 29 Commission on Base Realignment and Closure. The Commission was 30 chartered in May 1988 to recommend military installations within the 31 United States ’ €OK realignment and closure. The Congress and the 32 President endorsed this approach which removed some of the previous 33 impediments to base closure proposal. ?,‘I 35

2 1 There is general agreement within the Government that the National 2 Defense can be improved and its cost reduced through a more efficient 3 base structure. In the spirit of that general agreement, in December of 4 1988, the Commission recommended closure and realignment of 145 installa- 5 tions. Of these, 86 will be fully closed, five are to be closed in 6 part, and 54 will experience a change by an increase or a decrease in 7 mission personnel. That is called realignment. 8 9 The Commission released its report in December 1988, and, as you well 10 know, Jefferson Proving Ground was on that list as one of the 86 to be 11 closed. The Secretary of Defense accepted the recommendations in 12 January of '89. and beginning in March, Congress had 45 days to block 13 implementation of the law. That time expired and Congress did not block 14 implementation, and the law went into effect. 15 16 For those of you not familiar with the EIS process, I would like to . 11 briefly explain the requirements of the National Environmental Policy 18 Act, called NEPA. 19 20 This law is the basic national charter for the protection of the 21 environment and establishes policy and sets goals to ensure that Federal 22 decisions are made with a full understanding of the impacts the action is 23 likely to have on the human environment. In order to see that this 21 policy is carried out. the law establishes several procedures which 25 must be followed, the primary one being the requirement for preparation 26 of an environmental impact statement when the impacts can potentially be 27 significant. The purpose of this procedure is to assure that public 28 information is available before an action is taken and to help public 29 officials make decisions based on an accurate understanding of the 30 environmental consequences. The EIS process has been modified by the 31 Base Closure and Realignments Act. This modification provides that NEPA 32 does not apply to the actions of the Commission and to the Secretary of 33 Defense's acceptance of the Commission's recommendation. The law 34 specifically provides that "in applying the provisions of the Act, the 35

3 1 Secretary shall not have to consider three issues that are normally 2 considered in an €IS. First, the Secretary does not have to have an EIS 3 to consider the need for closing or realigning a military installation 4 which has been selected for closure or realignment by the Commission. 5 Second, the need for transferring functions to another military instal- 6 lation which has been selected as the receiving installation, or, third, 7 alternate military installations to those selected. What this means is 8 that NEPA does not apply to the decision to close or realign installa- 9 tions, but it does apply to how the bases are to be closed or realigned. 10 11 In these opening remarks, you have heard me refer to the EIS process, 12 and, indeed, the National Environmental Policy Act may most properly be 13 viewed as a law which does two things: It ensures an opportunity for 14 comprehensive involvement by individuals by various levels of Government 15 and by interested groups, and it provides decision makers--in this case, 16 the Army--with important information to help make the decisions. 17 18 In the case of Jefferson Proving Ground closure, the process began in 19 June 1989 when I held the scoping meeting to receive your comments and 20 concerns about the types of issues and implementation alternatives which 21 should be considered in developing this draft EIS. Comments, questions, 22 and suggestions were accepted for 15 days following that meeting. Subse- 23 quent to that meeting, an intense effort, involving data collection, 24 evaluation, and expert discussion was conducted. 25 26 Now, I ask you to pay particular attention to the next several para- 27 graphs that I am going to go over. 28 29 As the €IS process developed, it became obvious that cleanup and reuse 30 could not be fully addressed within the time allowed to prepare this EIS 31 which must be complete and a Record of Decision signed by the end of 32 September as required by the Base Closure Law. A cleanup and- future 33 reuse of Jefferson Proving Ground or other disposition of it will 34 require additional environmental documentation, most likely another 35

4 1 environmental impact statement. Preparation of that EIS will again 2 require the full spectrum .of public involvement from scoping to comment 3 periods, including another public meeting like the one you are attending 4 tonight. F. 6 What this means is, that tonight's draft €IS only covers actions up to 7 the point of closing Jefferson Proving Ground. The future reuse and n cleanup will be addressed in another environmental evaluation. 9 10 The way we had planned to address hazardous materials, including unex- 11 ploded ordnance, has also changed. Originally, a remedial investigation/ 12 feasibility study (RI/FS)--that means finding out what is there in terms 13 of contaminated soil, contamination of the environment, and unexploded 14 ordnance--finding out what is there. That is for remedial investigation. 15 The feasibility study is what do we do about it; how do we make it right, 16 by calling that an RI/FS. This was planned for the entire installation. 17 It was to identify all sources of contamination and help in developing a in cleanup plan. The Army still will proceed with a comprehensive RI/FS for 19 the cantonment area, which is south of the firing line. At this time, 20 associated activities north of the firing line will include monitoring of 21 selected sites and streams to determine if contamination is present in 27 concentrations hazardous to the public or the environment, or if hazard- 21 ous waste is migrating from the installation. So. at this time, we will 24 do monitoring in the northern area to determine if there are unhealthy or 25 environmentally hazardous situations, or if hazardous waste is migrating 26 from the installation. 21 28 Unexploded ordnance decontamination in the north area requires a unique 29 remedial investigation/feasibility study procedure in which cleanup is 30 accomplished when the unexploded ordnance is found, in this case the 31 RI/FS becomes a cleanup process itself. The Army believes that it is 32 premature to initiate the unexploded ordnance RI/FS over the entire area 3.J while viable reuse options exist. It may require a less extensive 3.2 clcanup. You may want to ask a question or two on that subject at the 35 proper time tonight.

5 1 At the door, we handed out the executive sununary of the draft environ- 2 mental impact statement. Now. on Page S-5 is a table (I know you can't 3 read this. except if you are in the very front rows), but on Page S-5 of 4 that is a table which summarizes the expected impacts of closing 5 Jefferson Proving Ground. 6 7 Generally, the environmental impacts that are considered beneficial are 8 due to stopping the current use and the disposal of hazardous materials 9 and the testing of ordnance. However, it is recognized that past use 10 and past disposal of hazardous materials will have long-term impacts. 11 12 Other positive impacts come from decreased discharges from the sewage 13 treatment plant, increased plant and animal resources due to stopping of 14 testing, and decreases in air and noise pollution. 15 16 However, socioeconomic impacts are expected to be significant. Approxi- 17 mately 421 positions will be eliminated at the Proving Ground, resulting 18 in an estimeted decrease of over 1200 people living in the region, and 8 19 decrease in regional income of $17 million. Regional sales of-goods and 20 servtces are expected to decline by $47 million. This is outlined on 21 Page S-6. Other factors for which impacts are summarized, such 8s ?? rn inera I resources, recreation, or transportation, will experience 1 itt le 23 or no impact. But you can see, and I sm sure you know, that the impacts 24 to the economy are going to be there.

2 '2

>(I On May 22, 1991. the Notice of Availability for this draft environmental /I Impact statcment appeared in the Federal Register. From that date, )A ttlcrv arc 45 days to allow public and agency comment, either in writing

I1 IILII I in8 lisL. There will be another public commenL period, this time i', )I) dnys long. We anticipate announcing the Final €IS in mid-August.

6 1 This entire process, including two public meetings and three comment 2 periods, is directed towards signing a document called the Record of 3 Decision, which describes the Army's decision and the basis for that

4 decision. Under the current schedule, the Record of Decision will be 5 signed no sooner than September 24 of this year. 6 1 Now, recall the decision that we are talking about is not whether to 8 close Jefferson Proving Ground. That is embodied in law; that is part 9 of law. The decision is how to close it. 10 11 Now, I am anxious to hear from you. If you have a written statement, 12 you may read it out loud, turn it in without reading it, or do both. In 13 any case, your comments will become part of the record. If you turn in 14 written comments, please write your name and address on them. With 15 that, I will open the floor. 16 17 We will first cover statements noted by those on the attendance cards, 18 and I will begin with elected officials or their representatives. I 19 would like to start with Sue Anne Gilroy, representing Senator Richard 20 Lugar. 21 22 MS. GILROY: I always love being first at times like this. I am @ 23 pleased to represent Senator Lugar this evening, and in so doing ask 24 that you use your imagination a bit for I will use the word, the pronoun, 25 "I" a number of times, but thifik of Senator Lugar when I do that. I 26 submit the following statement. ' 21 28 (Ms. Gilroy reads Senator Lugar's statement. This statement is one part @ 29 of a ?ledia Release by Senator Lugar, dated June 24, 1991, a copy of which 30 was submitted for the record.) See EXHIBIT No. 1. 31 32 I appreciate this opportunity to read Senator Lugar's testimony. and 33 request that it be submitted into the official record. Thank you. 34 35

7 COL PEIXOTTO: Thank you. It will be submitted. Thank you, Ms. Gilroy. Mr. Harold Gutzwiller from Senator Coats Office. To be followed by tlr. Wayne Vance of Congressman Hamilton's. Office.

MR. GLTZWILLER: Thank you, Colonel. I am here tonight on behalf of@ Senator Coats. I have his statement.

(Fir. Gutzwiller reads Senator Coats' statement, and submits same for the record.) See EXHIBIT No. 2. 10 11 That concludes my statement on behalf of Senator Coats. 12 13 COL PEIXOTTO: Thank you, sir. Mr. Wayne Vance of Congressman Hamilton's 14 Office. Followed by Mayor Wooden, City of Madison. 15 16 MR. VANCE: Colonel and members of the panel, thank you for the oppor- 17 tunity to discuss with you the Army's recently released draft €IS for 18 Jefferson Proving Ground. I regret that the Congressman could not be 19 present this evening for this meeting. 20 (Mr. Vence summarizes Congressman Hamilton's statement, and submits same for the record.) See EXHIBIT No. 3. 23 24 Thank you, Colonel. I propose this be submitted for the record. 25 26 COL PEIKOTTO: It will be. Thank you. Hr. Vance. Mayor Wooden. 21 28 MAYOR LOODEN: This is a joke. The joke started two-and-a-half-years0 L) 29 ago and the joke was the last meeting and this hearing is a joke.

30 Again, it appears that the citizens of Madison are being victimized by 31 sloppy incomplete staff work by the Army.

(Mayor Wooden reads his statement, and submits same for the record.) @I iz34 See EXHIBIT No. L. 35

8 1 In full conscience, I cannot believe how a group of individuals can sit 2 in those seats and not feel dirty, ashamed, or immoral, at their partici- 3 pation in a coverup of the nightmare that the Army is going to leave on 4 JPG. If this is the kind of neighbor and example that the Army is going 5 to set for environment, we need major changes. Thank you. 6 7 (Applause.) 8 9 COL PEIXOTTO: Thank you, Mr. Mayor. Mr. Robert J. Falls, Jr., AFGE 10 Local President. Followed by Mike Moore of the JPG Survival Committee. 11 12 MR. FALLS: On December 29, 1988, the Defense Secretary's Commission and@ 13 Base Realignment and Closure announced its supposedly objective list of 14 86 bases to be closed or realigned. 15 . 16 (Mr. Falls reads statement, which is one part of a large package of . material relating to Jefferson Proving Ground, which he submitted for 9 the record on behalf of the American Federation of Government Employees, 19 Local 2797.) See EXHIBIT No. 5. 20 21 I would like to take a moment to introduce the person that outside of 22 elected officials and S6L Managers has done more than possibly anyone 23 else to increase the national debt. Mr. Robert Jameson did more to 24 cause the closure of JPG than possibly anyone else by failing to pass 25 along corrective closure costs to the Base Closure and Realignment 26 Commission. Thank you, sir. 27 28 (Applause.) 29 30 COL PEIXOTTO: Thank you, Mr. Falls. Mr. !like Moore. Followed by 31 John D. Gay. 32 . 33 MH. MOORE: My name is Mike Moore, and I am the Media Liaison for the 06 34 JPG Survival Committee. It's a job that I fell into, didn't exactly 35 want it, but it seemed like that somebody needed to speak for the

9 1 employees, and the Survival Committee is an umbrella group that consists 2 of the American Federation of Government Employees, Local 2797, which 3 Bob Falls just spoke to you. And also middle management and the employ- 4 ees of Jefferson Proving Ground and financed, in part, by the merchants 5 in Madison, Ripling, Jennings, and Jefferson County. 6 7 The speakers that have spoke to you, I am not going to be able to add to 8 what they've said. What I am going to do is to explain to you informa- 9 tion that we have acquired over two years to show you that the basis of 10 this EIS has no basis. All the data that has been sent forward by the 11 Army to the Base Closure Commission have been a seat-of-the-pants type of 12 analysis where analysts would just draw on figures out of the air. They 13 wouldn't get out of their desks to try to do a decent analytical survey. 14 The entire documentation that the Army has based its study on is just hot 15 air. Jefferson Proving Ground was never involved in any of the data 16 collecting that contributed to its closure. It started at the Test 17 Evaluation Command, went up through the Army Materiel Command, and ended 18 at the Base Realignment and Closure Commission. They did not understand 19 what Jefferson Proving Ground did, they did not understand its function 20 in the Army, they did not understand that they test ammunition and that 21 they are the only post-based camp or station in the United States that 22 tests acceptance testing of ammunition in a grand and speedy and produc- 23 tive manner. Every place else it's fired is inefficient and it is 24 nonproductive. 25 26 Now, I'll start my statement. I have an executive summary, so that if it 27 gets too long, and someone wants to leave, that's okay with me. 1'11 28 just keep on going until I get it done. I'm going to raise this thing 29 (microphone) up. I'm a little taller than Bob was. 30

31 I want to thank you for the opportunity to address the Corps of Engineers 32 on the draft environmental impact statement. I am particularly-happy to 33 address Colonel David Peixotto, Corps of Engineers, Mr. Hike Early, Test 34 and Evaluation Company, and !lr. Robert Jameson. Army Yateriel Command, 35 bccause of the roles played by the respective offices in the closure Of 36 Jefferson Proving Ground.

10 JLil I 01 . : 7- 8-81 : 1:50AY ; Corps. of ENGINEERS4WAPORA / KEMRON :o 2

We 1 are hero tonight bmcAuse the Base Closure Commission of 1988 decided the saw monoy JPG's 2 that Govarnment could by moving mission to Yuma 3 Proving Ground, Arizona. To quote Governor Evan Bayh on his views on 4 the Commissions actions, "?hey thought they wore going to save monoy. 5 They're not going to save money; it is going to cost money to closo

JPG I' 6 . 7 8 1 am here todry to critique the draft environmental impact statement, 9 but firrt I Wnnt to place thir documont into a historical peripective. 10 Jefferson Proving Ground was designed and created by thm War Department 11 in tho lata 1930's to test firm ammunition and bomb8 being rapidly 12 produced by kaerican factories ar the nation prepared for war. During 13 World WAX 11,. no battlefield or city recoived more bombs or artillery 14 shells than the 52,000 rcror in Southern Indiana. There thousands of 15 ncrms spraad out over throe countisr have been aavaged for mor. than 50 16 years by tho most deadly devices crerted by mankind. Ghuyia K~hnand 17 his mongol hordes could not ravaga a countryside ao offoctively. 18 Two-thousand peoplo wers bodily moved from their ancestral homes in a 19 poriod of 30 days. Today, the only zrace of these once prosparour and 20 happy people arm 36 solid wastm management unirs, foundations of houres, 21 barns, churches, etc. Tho J6 SMi'o, by the way, Are the basis of tho 22 one-came closure costs of $57 million first submitted by TECOM, and they 23 wore quoting from an 11-year old report put out by USATHEMA. 24 25 Joshf, OXCUI~ mm for not saying hello. I nevor dreamed you'd be up thoro 26 and I'd be dawn hare. I'm vary glad. You distinguish the psnol. 27 28 (Laughtor.) 29 30 I appreciate your help in holping me understand the environmental laws. I spent about thcom wmmks with Josh1 jurt trying undorstsnd "RCRA" 31 to . 32 and "CERCLA. " 33 I have abcained transcripts of tha mlnutes of the BRAC I 1988 Commission 34 under the Freedom of Information Acr. Using those transcripts, GAD 35 1 documents, and the just released draft environmental impact statement, I 2 wish to define the cost data for you that the General Accounting Office 3 called flawed. It is amazing that the Pentagon and Congress have not 4 asked for clarification of this flawed data. It is my intent to explain 5 why the GAO says the data is flawed and to relate the actions and respon- 6 sibility of the U.S. Army Test and Evaluation Command (TECOM), and the 7 Army Materiel Command and the BRAC 1 Commission. 8 9 The GAO stated in his November 1989 report that the Secretary's 10 Commission on Base Realignment and Closure used flawed data and drew 11 erroneous conclusions that resulted in JPG being placed on the closure 12 list. ?he GAO found that in the case of JPG, the Commission erred by 13 (1) Understating construction costs to transfer JPG's mission to Yuma 14 Proving Ground, Arizona. by nearly 200 percent, not including environ- 15 mental cleanup as a cost closure. This cost was conservatively 16 estimated by the CH2M Hill Study commissioned by Governor Bayh by $550 17 million for service cleanup only. Including proceeds from the sale in 18 calculating the amortization period for closure, the GAO found that, due 19 to widespread ordnance contamination, it is unlikely that any JPG 20 property could be sold. 21 22 The Survival Committee believes that the bottom line is that, if 23 complete data had been used by the Base Closure Committee, JPG would not 24 be on the closure list and the State of Indiana would not be faced with 25 the prospect of 55,000 acres of Hoosier real estate rendered useless. 26 27 COL PEIXOlTO: Mr. Moore, if I can interrupt here, are you going to read 28 the entire eight pages? 29 30 VR. \100RE: Well, if you tell me to start skipping stuff, I'll start 31 skipping stuff. 32 33 COL PEIXOTO: Would you mind hitting the high points of it'please? 34 35

12 1 MR. MOORE: Sure. Do you mind if I go ahead to where it says, Cost 2 Analysis, on Page 4? I forgot this isn't double spaced. It kind of 3 doubles the length of it. 4 5 COL PEIXO'ITO: Your full statement will be in the record. 6 7 MR. HOORE: Okay. Well, I'll skip it as best I can and then we can stop 8 right there on Page L. -- I'll skip the review. We all know that there 9 is a public law. I'm going to skip down to where the BRAC 1 Commission 10 reported. Now, BRAC I is 1988. There is a lot of BRAC's running around 11 the Pentagon, and BRAC I is the one that put us on the closure list. 12 13 BRAC I Commission reported that the closure of JPG would save $6.6 14 million annually, and the one time closing cost would be paid back in 15 six years. The GAO, however, estimates savings of $6.3 million annually. 16 TECOM now estimates $3 million will be saved, so depending on what week 17 and what person you talk to, you get a different estimate. Now, the 18 payback is between 38 and 200 years. We're talking about an EIS of 19 something that would take the Government 200 years to try to clean up. 20 Now, I know the Army likes to quantify things, but that is getting a 21 little bit ridiculous. The Commission recommended a major realignment 22 of Fort Devans--this is what I'm getting to right here. You can skip the 23 rest of it. The Commission recommended a major realignment of Forts 24 Devons, Meade, Huachuca, and Holabird. It estimated an annual savings 25 of $21 million and costs will be paid back immediately. This is in 26 contrast to GAO estimates of annual savings of $8.1 million, with payback 27 periods OE 43 to over 200 years. 28 29 What I'm getting to is, the Secretary of the Army, Michael Stone, has 30 testified for the Base Closure Commission that it would nor make sense 31 to carry out the realignment of the Information Systems Command from 32 Fort Huachuca if it took 43 to 200 years to recover the cost. It is 33 okay to stop the realignment of Fort Huachuca because it rakes 43 years 34 to recover your money, but it apparently doesn't make sense to stop the 35 closure of JPG if it takes from 38 to 200 years to recover your money.

13 1 That is the point of all of it. I am trying to shw that fallacious and 2 skewed data is making up your EIS. Now, if a prosecuting attorney said, 3 you're not relevant, and the defense would come back and say, yes, but I 4 am preparing the groundwork for telling you that your €IS is based on 5 nothing, that is what I am doing. I am trying to get the groundwork in 6 here to tell you that you don't have an €IS. It is not environmental, 7 it is not an impact, and it is not a statement. 8 9 The thing that I don't understand here is that Representative Les Aspin, 10 Chairman of the House Arms Services Committee, held a press conference. 11 He said that the Commission erred; the Commission made a mistake. Here 12 is the guy that wrote the law saying that they made a mistake. He said 13 that BRAC 91. which is the third BRAC down the road, has the opportun- 14 ity to correct errors made in BRAC I, but we agree with Congressman 15 Aspin. Apparently so does the Department of the Army since it asked for 16 seven modifications to the BRAC I public law. 17 18 DOD cannot sell the Presidio. It stopped the realignment of the Infor- 19 motion Systems Command at Fort Huachuca. It cannot sell JPG without a 20 $5 billion cleanup. So. what will it be? Close the most productive 21 ammunition testing center in the country and cripple the Army's capability 22 to mobilize for war? I offer these comments on the draft environmental 23 impact statement. I have already said it. It is not environmental, it 24 does not discuss the impacts, and it is not a statement. 25 26 Now, I'm going to skip a whole bunch just for you guys, and I'm going to 21 go over here to where--1 get lots of letters from the Base Closure 28 people. In fact, I found out that if you write the President, the Vice 29 President, the Secretary of Defense, the Attorney General, the same guy 30 nnswe~~your letters, six or seven times. So, I've saved on postage by 31 just mailing it to this one guy. 32 . 33 CO1. PEIXOTTO: Do you get the same answer? 34 35

14 1 flR. MOORE: I get the same answer, the same letter. Although, occasion- ,* 2 ally, he does say, As I told you previously through your letter to the 3 Vice President," blah, blah, blah! 4 5 The whole thing I am trying to say is that we got started off on a bad 6 foot. The people that are in charge of representing us at DOD, they 7 have a vested interest to keep us closed. They don't try to bring forth 8 corrective data. Now, the test and evaluation men, six days after it 9 submitted its cost data, sent up a double factor of one-time costs. 10 They said it was $95 million. Well, that data didn't get to the BRAC I 11 Commission. What we're saying on this environmental statement, the data 12 generated at JPG is not getting into that environmental impact statement. 13 14 I'm going to leave, but this is Jack Katzen, and if you fellows have 15 been at DOD in the Pentagon, back in 1989, he was the Director of the 16 Base Closure Office, or at least that is the way he signed his document. 17 He stated that environmental costs were not used in determining the ia payback period. An environmental survey will be conducted to determine 19 ~ctual cleanup costs associated with the ordnance problem. Based on 20 knowledge of cleanup costs at similar installations--remember JPG is 21 the only installation of its kind--but Jack says, at similar installa- 22 tions, the cleanup costs for unrestricted land use is estimated to be on 23 the order of $30 million. Can you imagine now saying that it would take 24 $30 million to clean up JPG? Well, just a few months later, same guy, 25 Jack Katzen, only this time he wrote the letter to the Honorable Lee H. 26 Hamilton, he said, "The initial $30 million estimate for unrestricted 21 land use is inaccurate." Now, he didn't even apologize for the crummy 28 data that he was speaking before, and we're being closed on the basis of 29 guys like him who have been fed incorrect and grossly inadequate 30 informat ion. 31 32 Now, there is one other little map back here in the exhibits, and if I 33 submit Lhis, the exhibits will get in there too. There is a little map 34 back here that I stumbled on in the records. It is 1969, and it shows 35 firing ranges at the south end of the Proving Ground. Over here on the

15 1 right-hand side, it says, southeast test ranges, and it's got one, two, 2 three, four impact fields there. Now, this is grenades, rockets, and 3 mines. Over here by the airport in the south end, there is one, two, 4 three, four more impact fields, and there is another map I have that has 5 an ammunition dump there at the airport. 6 7 Now, this is one little kicker that a retired €OD person told one of the 8 employees, and EOD is Explosive Ordnance Disposal. After Korea, they 9 had unexploded projectiles piled sky high around JPG. They dug pits out 10 around F Firing position, where we fired today, and they buried truck- 11 load after truckload of high explosive shells. Nw, nowhere do I see 12 anything like that in this EIS, or this draft. So, thank you very much. 13 That is all I've got to say. 14 15 (Applause.) , 16 (Mr. Moore submits his complete statement, along with other documents, q 18 for the record.) See EXHIBIT No. 6. 19 20 COL PEIXOITO: Mr. John D. Gay will be following that fine presentation 21 by Mr. Moore. 22 23 MH. GAY: Simply eloquent. I have a policy resolution from the Hoosier @ 24 Environmental Council to read to you and submit to you. It doesn't 25 address the problems that have been addressed by many of these people in 26 regard to the loss of jobs or the soundness of the decision to close the 21 JPG, it merely addresses what we see as many of the environmental prob- 28 lems that are present by the closure of JPG. After that, I would like to 29 make a brief statement of my own in regard to this. I am a resident of 30 the Town of Versailles. I am affected by it. 31 32 (Mr. Gay reads the HEC Policy Resolution, signed by Mr. Albert. Tinsley 33 and dated March 23, 1991, and submits same for the record.) 0 34 See ESHIBIT No. 7. 35 I reviewed the environmental impact statement to find that it does little to identify the contaminants that are present. It does nothing to state how the Army plans to clean them up. In fact, what it does do, and it makes it rather clear to me, that the Army intends to use this indefinite standby status as a caretaker. I suspect it will indeed be indefinite. It intends to harvest timber, and if you read carefully through the environmental impact statement, you will note that, although it doesn't find it anywhere, the Army suspects that there are many contaminants on this property, not including probably the most dangerous contaminant, the unexploded ordnance. It also notes that this contamination may be carried off the property through groundwater, although they will monitor this.

Then it goes on to propose that they harvest more timber and increase the erosion and increase the probability that these contaminants are carried offsite. I propose that the Army not do so. To do so endangers residents and nearby communities. In fact, the Army has indicated that it doesn't intend to do much of anything to make up for the withdrawal of the resources, the use of the facility, the provision of jobs, the income that goes along with that.

Real estate generally generates income in one form or another. The prOpOS61 to turn this into an indefinitely cared-for piece of property will do none of that. The proposal to clean it up--I would propose to the people here in the audience, if we make the Army clean it up, there is going to be more jobs, there is going to be more money spent in this area than they will ever spend by dumping bombs on the aree, exploding ord- nnnce, spraying herbicides on it to make the ground barren so that they can see where the ordnance falls. I don't want to see the loss of jobs

111 this community. It is a poor community. It is a poor area. The iiicomr is important. The Army just cannot be allowed to simply close this property and walk away. If it is going to close the property,. it hils got to clean it up and return the resource to some sort of income

~,.L 3Ltivity. If it is just hunting, fishing, and a natural preserve type of 35 area, it will provide some income to replace that which is withdrawn by 36 the Army. Thank you.

17 1 (Applause.) 2 3 COL PEIXOTTO: Thank you very much, tlr.. Gay. That is the last of the 4 people who indicated ortheir cards that they wished to make a statement. 5 I would like to open it up now to anybody that has felt the urge in 6 hearing what others have said to either make a statement on their own or 7 to come up and ask any questions that you might have. 8 9 If you wish to do that, please come forward and state your name. If you 10 represent soneone, state whp you represent, and please make your state- 11 ment. Yes ma'am? 12 13 MS. HAWVERMALE: Good evening, ladies and gentlemen. My name is Greta 14 Hawvermale, and I am here tonight representing the Indiana Department of 15 Environmental Management, and not doing a very good job of it. I am a 16 Branch Chief with the Indiana Department of Environmental Management in ' 17 the Office of Environmental Response, Project Management Branch. 18 19 I just have a couple of brief comments. The Department is currently 20 conducting a technical review of the draft environmental impact state- 21 ment, and we are preparing extensive written comments which will be 22 submitted within the prescribed comment period. %j

21 For tonight's record, the Department has serious concerns about the 2 5 information and recommendations contained in the draft environmental impact statement. The study does not propose a comprehensive environmental investigation of the site, particularly as it omits the significant portion for evaluation, that is those areas impacted by unexploded ordnance. This and numerous other technical concerns will be identified in greater detail in our written comments. Thank you. 31 32 COL PEIXOTTO: Is there anybody else who wishes to make a statement, ask 33 questions? Yes sir? 3 4 35

18 1 MR. MCCLELLAND: My name is Tom McClelland. If you would look at the 09 2 patch on my shoulder, you would read it says, Jefferson Proving Ground. 3 And if you were to take and look at the badge that is on my chest, you 4 would read, Fire Protection Division. And if you were to take and read 5 the service board at the Jeffersonian in JPG, you would read 20 years of 6 service. 7 8 Now, I am not an official spokesman for Jefferson Proving Ground, but I 9 come to you making a statement as a taxpayer for Jefferson County, and 10 for the State, and for the United States. So, I address you as a 11 taxpayer, a taxpayer who must support this decision one way or another 12 through my tax dollars. I am a taxpayer just like the people who made 13 up the area back in 1941, when the land was taken in 30 days. They 14 supported the making of JPG by giving up their homes, their churches, 15 schools, and farms. You took and referred to a law which stated several 16 requirements to be met by law. The law as I understand it says that the 17 Base must be closed and the property sold. I am a bit confused. We're 18 going to take and sell JPG for $25 million, and we're going to spend 19 $112 million for construction at Yuma Proving Ground to do the same 20 thing that we are doing at JPG. And you hava not come up with any kind I 21 of a dollar figure as I see for the cleanup of JPG, for it to be sold. 22 It is my understanding that the cost must be recouped within a six-year 23 period, by law. My concern is simply this. How old will I have to be 24 or how old will my unborn child have to be before we pay for this 25 decision. Thank you. 26 21 (Applause.) 28 29 COL PEIXOTTO: Thank you, sir. Excuse me, did you fill out a card? 30 31 ?IR. MCCLELLAND: Yes sir 32 . 33 COL PEIXOTO: Tom McClelland, thank you. -- Anybody else? 34 35

19 1 MR. BROWN: My name is William Brown, and I filled out a card over at c 2 JPG. You're talking about people going out and cutting timber and so 3 on. I do believe they closed a base down in Arkansas in 1948 or so. 4 There has been people killed there. People out here where they are not 5 supposed to be'are going to get killed. Who is responsible for that? Is it the State of Indiana, or is the Army going to pay for the deaths (91: of people who are going to get killed out here when this base is closed? 8 9 COL PEIXOTTO: That is a legal question. Does anybody up on the panel 10 have an opinion on that? 11 12 MR. BROWN: And it will happen too. ! 13 I , 14 COL PEIXOTTO: I guess the Courts will sort that one out. The Army will 15 have the responsibility to do it best, to keep people out of areas where 16 they shouldn't be that are dangerous. ... 11 18 MR. BROWN: If you open it up for timber and hunting and fishing, how 19 are you going to keep them out? 20 21 COL PEIXOTTO: I have given the best answer that we have at this point. 22 You have asked a very difficult question, and that will be one that we 23 will have to address in the reuse of this facility. Remember this 24 environmental impact statement that we are discussing tonight goes up to 25 the point of closure, and we will have another environmental impact 26 ztiltement on reuse, and that is something that is going to have to be 21 Jddressed very thoroughly in that. -- Yes, the gentleman here. 28 29 YAYOR WOODEN: Yes. Mayor Wooden again. I just want to make a comment 30 on one of your original statements, and that was the intent in the 31 spirit of the law. There is nothing closing JPG down that goes along 32 with the intent and closure of the law. That law has been changed. with 0 i3 modifications and, as of today, the Army still has not given one, not 15, 34 not three. not even one, legitimate reason for closing JPG down. Just 15 please keep that in your mind while you do your work.

20 (Applause.)

COL PEIXOTTO: Thank you, Mr. Mayor.

MR. WYCOFF: My name is Jack Wycoff. I work with this gentleman over @- here that's got 20 years on the Board out there. I've got one question 7 concerning the closure. If, indeed, the Army does close JPG and with all intentions, they intend to do so, what intention does the Army have to 0;cnsure that the same process doesn't happen again in Yuma? How are they 10 going to clean that place up as they go along? Are they going to do it 11 again in 50 years, and who is going to suffer after they leave? 12 13 (Applause.) 14 15 COL PEIXOlTO: Thank you, sir. 16

17 UNIDENTIFIED MAN: I have a question for Mr. Jameson. Mr. Jameson, it is 18 my understanding that you were the one responsible for not passing 19 forward corrected money data figures to the Base Closure Commission. Is 20 that true, sir? 21 22 HR. JAMESON: No, that isn't true 23

24 UNIDENTIFIED MN: It is my understanding that twice corrected data was 25 sent to you and it was not passed onward to them. 26 27 MR. JAMESON: We passed on the data that the Base Closure Commission was 28 an independent Congressional appointed Commission. They did their own 29 analysis. We passed on whatever data that was questioned by that 30 Commission. 31

32 UNIDENTIFIED MAN: Well, sir, I don't think you are fully answering it 33 34 COI, PEl.YOTI'0: Anybody else? Yes sir? 35

21 1 MR. MOORE: I would like to ask a question. 2 3 COL PEIXO'ITO: No, you don't get to do pages 4 thru 8 now. 4 5 (Laughter.) 6 7 MR. MOORE: I'd just like to ask Joshi this question, only because I@ 8 know him and I know that he knows the laws pretty well on base closure 9 as far as environmental goes. Joshi, in the Madison Courier Saturday, 10 the AP came out with a story about the Senate Arms Services Committee. 11 This was an Air Force--Assistant Secretary of the Air Force--he said 12 that the environmental laws hamper base closure because they won't let 13 us divide up a base and clean up portions and sell them, that we have to 14 attack the whole base, clean it up, and then sell the whole base. Now, 15 if that is true, what exactly are we doing here tonight because this EIS 16 is, from the way I understand it, considering the southern 3,000 acres. 0 17 That is parceling JPG up, and the way I understood this article, this 18 Assistant Secretary of the Army--1 think his name was Vest--stated that 19 you have to clean the entire base as a whole. Do you know anything 20 about that or can you shed any light on that? 21 22 MR. JOSHI: This news that you are mentioning here, in my view, environ- 23 mental laws should not hamper the base closure process. I think the Army 24 is required by the law to do the cleanup if these laws are applicable to 25 a portion or the whole Army base. So, without knowing the whole content 26 on this news that you are talking about, I don't think I can answer you 21 fully. - 28

29 MR. MOORE: Well, like I say, I just read it Saturday. It was kind of 30 news to me because I was kind of thinking that way, but I wasn't sure. 31 If you don't ntind, could you send us a copy of that law or talk to 32 somebody about whether they can parcel out a place and sell parts of it 33 or not? Because that would really have a bearing on this EIS. . 34

35 HR. JOSHI: That is base closure with realignment law. Right?

22 1 MR. !IOORE: Yes. Apparently, they say that you cannot parcel out an 2 installation. Like they closed Peace Air Force Base in New Hampshire. 3 Well, they're having difficulty because they've got a buyer but only for 4 a portion of it, but they have to clean the whole thing up, you know. 5 They can't just clean part of it up. So, it seems to me like it would 6 apply here to JPG. I knw it is kind of springing it on you, but I just 7 read it Saturday and it is enclosed as an exhibit at the end of my 8 testimony there, that AP Article. It talks about Senator Allen Dixon 9 also. So, I would appreciate it if you could get that information 10 because it would make a whole lot of difference in the way we attack 11 this EIS. 12 13 MR. JOSHI: Yes, I saw that copy this afternoon, but I have not read it 14 completely, and like I said before, without knowing the background 15 information, I don't think I can answer you fully. 16 17 MR. fi00RE: Well, I didn't really expect you to. 18 19 MR. JOSHI: In my view, environmental laws should not hamper the base 20 closing process. 21 22 MR. HOORE: Well, that was the headlines on the whole thing. Said, 23 "Environmental Law Hampers Base Closure. I, If you could find out something 24 for us, we'd appreciate it. 25 26 MH. JOSHI: I will try, definitely. 27 28 COL PElXOlTO: Mr. Jameson, would you be able to respond from an AHC 29 prospective as to whether when a portion is cleaned, if that can be sold 30 off or whether the entire installation must be cleaned first? 31 32 MR. JAMESON: I think I can say probably the Army has a policy that they 33 would go at it piece-meal. They can clean part of the installation up 34 and the surrounding acreage would not have any problems with contami- 35 notion of it, so that the parcel that could be sold would be safe

23 as far as health and safety. I don't know about the Air Force. Like Joshi, I have not read the article, but I kncu the Army's policy is that they can clean it up and reuse or sell off part of the land.

COL PEIXOlTO: Thank you.

MR. WYCOFF: Jack Wycoff again. I've got one more question for you.@ Whose decision was it to do this EIS on the 3,000-acre cantonment area only? 10 11 COL PEIXO'ITO: The EIS was not done on the 3,000 cantonment area. The 12 EIS was done on the entire closure of JPG. 13 14 MR. WYCOFF: Well, if it was done on the entire closure, why didn't we 15 include the entire scope of the problem? I mean, we left out the big 16 problem of the UXO. and we are saying that this EIS pertains to JPG as a 17 whole. That is a fallacy. 18 19 COL PEIXOTO: The EIS pertains to JPG as a whole, but it only takes the 20 Army's actions up to closing the installation. It doesn't take the 21 Army's actions into the RIFS, into finding out what contamination is 22 and planning for its cleanup on either the 3.000-acre or the other 23 51,000 acres. 24 25 MR. WYCOFF: If I can use an example, if I was to go to the Small 26 Business Administration and tell those folks that I want to start a 21 business over here, the first thing that the Federal Government requires 28 of me is a business plan. Okay? And if I bring them a plan that says 29 that here I want to start "XYZ" business and I'll give you the plan next 30 month, vhat do you think those folks are going to tell me? 31 32 COL PEIXOTO: This plan is your business plan for starting. It is not a . 33 plan for cleaning up and reusing. 34 35

24 1 MR. WYCOFF: But it is incomplete; that is part of the process--required 2 by law. 3 4 COL PEIXO-0: And you are saying that because it doesn't go into 5 cleanup and reuse, it is incomplete? 6 7 MR. WYCOFF: I am saying because you didn't address the total problem 8 with the cleanup of JPG, this first EIS is incomplete. 9 10 (Applause.) 11 12 COL PEIXOTTO: I understand your point of view. Thank you, sir. -- 13 It's been quiet in the back there. 14 15 MR. VORIS: I'm not very bright, but what I've heard go on here tonight-- 16 My name is Ray Voris, and I filled out one of those cards when I came 17 in. As I was listening to these individuals speak to a panel and as I 18 observed, I don't know how much went in and really I don't really think 19 much. I think what we are fighting here is the Government. And the 20 problem is that we are only citizens. You know, Lee Hamilton was at the 21 Proving Ground on our 50th Wedding Anniversary, which is coming to a 22 close real soon. And he said, the people of this community gave up 23 their homes in 30 days. But you know, it only took about six months for 24 a panel to decide--not even coming to this community, not even looking 25 Jefferson Proving Ground over and the stats that they have. You know, 26 I've lived in this community for 50 years. I never worked there until 27 about four years ago. I was a guard. If you get at one end and you 28 drive around it, it takes you 40 minutes. That is from here to Louis- 29 ville. That is just part of the fence. We have poachers that come 30 in there. We have people that come in that place. It is a potential 31 hazard. But you know, when you get up and you begin to talk about these 32 things, these won't be brought up, because it's immaterial. It's 33 immaterial, human life is, to you people. Dollars and cents d'on't mean 34 ;Irlything to you people either because you've got a blank check. But as

35 ,111 iiidividual and a taxpayer and a person that works at Jefferson

25 1 Proving Ground, how many of you have really stepped onto the place and 2 found our what we really do out there as an individual. You say you're 3 Army. I'm Army! I work at Jefferson Proving Ground. I take a paycheck 4 home every two weeks. But you know what? I'm going to have to move my S family to Yuma, or someplace else. But, do you care. Do you care that 6 all of us in the room have to move our families. No. Because you're 7 not being touched. 8 9 You know. these Congressmen, they sit in their places and they talk big 10 talk and they write good letters. But let's put them on Jefferson 11 Proving Ground in the contamination area and see how long they'd stay 12 there, their children and their grandchildren. You know, let's get real 13 what we're talking about here tonight. We're talking about displacing 14 1200 people, taking $47 million out of this community and surrounding 15 communities. But you know what, that only means something to me as an 16 individual. 17 18 The Bible says that "There is wars and rumors of wars." But you know 19 what? We're down-scaling our Army, down-scaling our Army. You know 20 when I look at the map and I see where all the munitions are made in the 21 United States, we are centrally located. But we want to spend money to 22 truck them from the central location all the way to the west coast. 23 When none of this stuff is taken into consideration, must not have been 24 by the Realignment Committee, because none of this stuff was discussed. 25 Not probably one of them stepped foot on Jefferson Proving Ground to see 26 what we do. We're only a little hole in the wall, 55,000 acres in the 21 middle of the southern part of Indiana. 28 29 Yeah. we can only talk about four pages because we don't want to hear the 30 rest of what is going on. We're in a hurry to get this meeting over 31 with so we can' go home to our nice comfortable air conditioning. But 32 you know. to me as an individual, I am interested in Jefferson Proving 33 Ground, and the future of Jefferson Proving Ground. Not Yuma; Arizona. 34 I don't went to live in Arizona. I didn't buy a home in Arizona. I '1 5

26 1 wasn't raised in Arizona. I was raised in Madison, Indiana, and I'd like 2 to stay here. But you know, I'm not Army enough to say, give me some 3 place to stay for 16 years. No, I move every two years in the Army, 4 every four years. 5 6 I appreciate you listening to me. I probably rattled on. But you know, 7 30 days is all it took them to move off of 55,000 acres, and we've 8 talked about this thing since 1900. And no monies for building in Yuma 9 has come forth yet from Congress. All I've ever heard about from our 10 Commander is that we are going to close, we're going to close. We don't 11 know when. And I go to work every day. If the gate is open, I drive 12 through. But some day, I'm going to drive over there and the gate is 13 going to be closed, and I'm going to have to turn around and go back 14 home. That is what I've learned in four years at Jefferson Proving 15 Ground. 16 17 I appreciate you listening to me. Think about it. And Mister, do you 18 know, we just fought a 100-day war. And we praise and we parade up 19 and down the street saying what kind of a backbone we have. But you 20 know, we've got some yellow bellied people that was on realignment that 21 won't come forth and say they made a mistake. That's what it's all 22 about. All they have to do is to come forth and say. hey, we didn't do 23 our job. That's all they have to say. We didn't do our job. That's 24 it. But you know. they won't do that. Because it might make them not 25 look good because they owned up to making a mistake. Thank you. 26 21 (Applause.) 28 29 COL PEIXOTI'O: Thank you. That was very well spoken and very heartfelt. 30 Thank you very much.' Anybody else? I trust that you understand that the 31 decision to close--I know you have been told this before--the decision 32 was made by the Commission and until the law is changed, that is the 33 decision that we are facing and are moving forward and implementing. I 34 know it is a bitter pill to swallow, and you are right, it doesn't affect 35

27 1 me personally, in my personal life. But it affects me emotionally coming 2 to a place like this and hearing this. But until the law is changed, 3 then we have to move ahead with what the law says. Yes sir. We need to 4 get you on the mike here. 5 6 UNIDENTIFIED MAN: Just a quick one. Whose idea was it to do this in two 1 parts, covering up to, you said, base closure? 8 9 MR. JAMESON: That decision was made at the Department of the Army, 10 Secrecary Stone, and Ms. Susan Livingston, who is the Assistant 11 Secrecary of the Army for Installations and Logistics and Environment, 12 made the decision to do the environmental into two separate packages-- 13 one to close and realign and one for reuse of the Proving Ground. 14 15 COL PEIXOTTO: The answer was, in the Secretary of the Army's Office. 16 17 MR. VORIS: This is off the record. You keep saying it is the law, 18 but I have heard about two or three bases coming off the closing list. 19 You keep saying it is by law, but by law, where does these others come 20 off? Do you have an answer to that? 21 22 COL PEIXOTTO: I am not aware of any coming off the list. Does anybody 23 else? 24 25 HR. VORIS: How about the Presidio? 26 21 COL PEIXOmO: As far as I know, it is still--how about what? 28 29 MH. VORIS: What about Huachuca? 30 31 COL PEIXOTTO: Huachuca was never going to be closed. They were moving 32 some missions from Huachuca to Fort Devons. 33 . 34 YR. VORIS: It was part of the law. 35

20 1 COL PEIXOTTO: It was part of realignment, not closure. 2 3 MR. VORIS: It was part of the law for base realignment and closure. 4 5 COL PEIXOTTO: Base Closure ‘91 is going through the process of becoming 6 law, and part of BRAC 91 is Fort Devons which the Huachuca stuff was 1 moving to. So, if that becomes law, then there is no home for the stuff 8 coming out of Huachuca. You’ve got one law saying 1, move it there“ and 9 the second law says, “it can‘t go there.” 10 11 HR. VORIS: So, if you are going to change the laws, then change the law 12 to make it all correct. 13 14 COL PEIXOTI’O: Sir, you know I can’t change the law. You know nobody at 15 this table can change the law. 16 17 MAYOR WOODEN: What about the recommendations. Why don’t you speak out 18 instead of just standing there? You say, this is the way it is, but in 19 reality, it is not that way. 20 21 COL PEIXOTI‘O: It is that way until the law is changed. Yes sir? 22 23 MR. BROWN: You talk about laws and honesty. The gentleman up there 24 knows that this was supposed to be aboveboard and impartial, but, yet, 25 then Governor Robb of Virginia took one of the two men who were heading 26 up this Committee to Virginia to a little Fort, showed him 12 rounds 2 7 laying in a pond that had been there for over a hundred years, and they 28 said the cost of about $7 or $8 million to clean that up was too much, 29 and it was taken off. And you are telling us that everything that has 30 been around here is aboveboard. Why was that one taken off? Even 31 before it was started, it was taken of€ because they did something they 32 weren’t supposed to do, by a Governor taking a man down there and 33 showing him something. . 34 35

29 1 COL PEIXOTTO: All I can say is that it never became part of the closure 2 list. I know this is a painful wound and we're picking at a scab on 3 this. Until the law is changed, we are what we are. 4 5 MR. VORIS: I want to go on record tonight as saying, Colonel, you are 6 standing before us and you have an opportunity to change what is taking 7 place at Jefferson Proving Ground. You have an opportunity. You are 8 here to listen to the public and you can leave this place and you can do 9 something about it. I believe that. The panel up there can do something 10 about what is taking place at Jefferson Proving Ground. That's all you 11 have to do is to share with them what went wrong and we want to fix it, 12 and we can fix it now before it gets too late. That's all you have to 13 do. You can start by doing it tonight. When you go back and write up 14 your scenario of what took place in this building tonight, you can take 15 all the information you got and you can begin to share honestly and out 16 front, and things can happen, Things can happen. But like I said when I 17 first started, if you don't hear a word that we are saying, nothing is 18 going to be changed. Nothing. We are doing nothing but blowing hot 19 air. Yes sir. That's right. 20 21 (Applause.) 22 23 COL PEIXOTTO: Anybody else? Last chance. -- I want to thank you for 24 coming tonight, and I appreciate your open and frank remarks to us. That 25 will be helpful as we prepare the final environmental impact statement. 26 27 1 would like to review the schedule one more time and remind you that 28 you have until the 8th of July to get your comments in--you have until 29 the end of the 65-day cment period to get your comments in. 30 31 I thank you all for coming tonight. I appreciate your attendance. 32 33 14 .'li!vLing adjourned at 9:15. Madison, Indiana, time (EST). 35

30 IV. EXHIBITS

Exhibits are avai lablc iupoti request. IV. REGISTERED ATTENDANCE REGISTERED ATENDANCE AT PUBLIC MEETING HELD AT THE MADISON HIGH SCHOOL, MADISON, INDIANA ON 24 JUNE 1991 CONCERNING BASE CMSURE OF JEFFERSON PROVING GROUND

Organization Represented Name and Title Address or Subject of Interest

Abner, Lynne 315 Golf Ridge Lane Jefferson Proving Ground Madison, IN 47250

Baldwin, Carolyn 2151 Flint St. Self Madison, IN 47250

Bayne, Bob 801 W. 2nd Jefferson Proving Ground Madison, IN 47250

Bayne. Patricia 1009 w. 1st St. Self Madison, IN 47250

Bayne, Wilford, Jr. 1009 w. 1st St. Self Madison, IN 47250

Belou, Robert 834 West 3rd St. Self Madison, IN 47250

Borns, Nicholas F. 1907 Cragmont St. Self Madison, IN 47250

Brown, William R., Sr Route 7, Box 207 Jefferson Proving Ground Madison, IN 47250

Cantwell, Bruce 512 Brentwood Self Madison, IN 47250

Castelli, Peter M. 10 W. Market, Suite 1180 Senator Richard G. Lugar Indianapolis, IN 46204

Clark, J. M. 123 U. 3rd St. USA JPG Madison, IN 47250

Cochran, Becky 1180 Market Tower Senator Richard G. Lugar 10 W. Market Indianapolis, IN 46204

Congleton. Robert C. Rural Route 85. Box 273 JPG M&D-TI Madison, IN 47250

Cooke. Bob and h23 E. Main St. Self Barb Madison, IN 47250

Cooper, 5rs. Polly 2237 Clifty Hollow Rd. Self Nadison, IN 47250 REGISTERED ATENDANCE AT PUBLIC MEETING HELD AT THE MADISON HIGH SCHOOL, MADISON, INDIANA ON 24 JUNE 1991 CONCERNING BASE CLOSURE OF JEFFERSON PROVING GROUND

Organization Represented Name and Title Address or Subject of Interest

Daghir, David M. 2135 Michigan Rd. City of Madison Madison. IN 47250 JPG Development Commit tee

Dionne, Dave 1335 Clifty Drive JPG Reuse Committee Hadison, IN 47250

Dixon, Robert Rural Route 1, Box 51 Self Madison, IN 47250

Dwyer, Jack 333 Highlan Dr. Self Madison, IN 47250

Eaglin, Joy R1 Chain Hill Jefferson Proving Ground Hanover, IN 47243

Early, Michael J HQ USA TECOH Test h Evaluation CMD Am: AEISTE-PL Aberdeen Proving Ground HD 21005

Edwards, Eric 624 Huhammad Ali Blvd. WDRB Channel 41 News Louisville, KY 40203

Ehlert, Allyn L. 449 Bellaire Dr. Jefferson Proving Ground Madison, IN 47250

Falls, Robert J., Jr. Jefferson Proving Ground AFGE Local 2797 President Madison, IN 47250

Fletcher, Scott T. 1815 Centruy Blvd. Ste 150 Wapora, Inc. Contractor Atlanta, GA 30345 Contractor on Project

Fritsche, Jim 1202 N. 500 East Self Columbus, IN 47203

Gauger, Robert 'G 161 Bunton Ln. Self Madison, IN 47250 . Gay, John D. P.O. Box 413 Hoosier Environmental Versailles, IN 47042 Council

Geisler, Albert E. Route 1, Box 146 JPG Survival Madison, IN 47250

2 REGISTERED ATENDANCE AT PUBLIC MEETING HELD AT THE MADISON HIGH SCHOOL, MADISON, INDIANA ON 24 JUNE 1991 CONCERNING BASE CMSURE OF JEFFERSON PROVING GROUND

Organization Represented Name and Title Address or Subject of Interest

Geisler, Barbara Rural Route 1, Box 146 Self Madison, IN 47250

Getty, Alyse G. 1815 Century Blvd. Wapora, Inc. Suite 150 Atlanta, GA 30345

Gilroy, Sue Anne 1180 Market Tower U.S. Senator Richard 10 W. Market Lugar Indianapolis, IN 46206

Gohn, Tom and Carol 235 Cedarwood Instrumentation at JPG Madison, IN 47250

Grant, BeKKy J. 302 Mouser JPG Madison, IN 47250

Guljas, Ed Rural Route 1 Self Commiskey, IN 47227

Gutzwiller, Harold 1201 E. 10th St. U.S. Senator Dan Coats Room 103 Jeffersonville, IN 47131

Harper, Anthony L. DBD/OEA WD/OEA 3B 4C767 Washington, D.C. 20301

HQ TECOM. Am: AHSTE-JA USArmy, Test h Aberdeen Proving Ground Evaluation Command HD 21005-5055

Hawvermale, Greta Office of Environmental IN Dept of Environmental Response Management (IDEH) 5500 W. Bradbury Indianapolis, IN 46241

Herring, Richard H. Box 111 JPG Canaan, IN 47226

Ilodges, Laura Madison Courier Madison Courier 310 Courier Square Madison, IN 47250

3 REGISTERED ATTENDANCE AT PUBLIC MEETING HELD AT THE MADISON HIGH SCHOOL, MADISON, INDIANA ON 24 JUNE 1991 CONCERNING BASE CLOSURE OF JEFFERSON PROVING GROUND

Organization Represented Name and Title Address or Subject of Interest

Holr. Charles V. 309 Crestwood Dr. Self Madison, IN 47250

Hoskins, Owen L. 2235 Ross St. JPG Madison, IN 47250

Humphrey, Leroy A. Rural Route 5, Box 493 Self Madison, IN 47250

Huntington, Glenn 433 Mouser St., Apt. 46 Self Madison, IN 47250

Hyatt Tony One Independence Square VDRB-TV Louisville, KY 40201 News at Ten

Jerre 1, Dennis H. 138 Elmhursr Lane Self Madison, IN 47250

Jones Larry R. Rural Route 1, Box 107 U.S. Army Lexington, IN 47138

Joshi, K. N. U.S. Army Toxic and U.S. Army Toxic and Hazardous Uaterials Agency Hazardous Materials Edgewood Area Agency Aberdeen Proving Ground MD 21005-5055

Karns, Daryl 103 Young St. Self Hanover, IN 47243

Klopp, Wanda 2249 Martha Place JPG Madison, IN 47250

Knouf, Kenneth G. Route 2, Box 22 JPG Survival Committee Xadison, IN 47250

Long, Janet 1834 Crozier Ave. U.S. Army Jefferson Madison, IN 47250 Proving Ground

Lyons, Patrick S. 238 Ciao St. Jefferson County Comm Hanover, IN 47243

Marshall, Ken 7255 Floyd St. WAVE -Tv Louisville, KY 40232x ,4

4 REGISTERED A'ITENDANCE AT PUBLIC MEETING HELD AT THE MADISON HIGH SCHOOL, WISON, INDIANA ON 24 JUNE 1991 CONCERNING BASE CLOSURE OF JEFFERSON PROVING GROUND

Organization Represented Name and Title Address or Subject of Interest

Maslyk, Louis J., Jr. 461 Woodland Rd. ?tichael Baker Corporation Canonsburg, PA 15317 for Louisville District Corps of Engineers

McClelland, Chris Route 1, Box 69 U. S .Army Dupont, IN 47231 Jefferson Proving Ground

McClelland, Pam Rural Route 6, Box 1 181 TFG IN-ANG Madison, IN 47250

McClelland, Thomas D. Rural Route 6, Box 1 Jefferson Proving Ground Madison, IN 47250

Meek, Kenneth E., Jr. Rural Route 1 Jefferson Proving Ground Dupont, IN 47231

Meek, Ken, Sr. Box 127 Self Dupont, IN 47231

Minett, Del 2011 Gumtree Terrace U.S.Army TECON Bel Air, MD 21014 APG, MU

Moore, Allen 317 Green Road Supply Services 6 and Brenda Madison. IN 47250 Transportation, Jefferson Proving Ground

Moore, Mike 242 Crestwood JPG Survival Committee Madison, IN 47250

Morecraft, Dana J 320 Hendricks St. Self Madison, IN 47250

Munier. Louis 2250 Wilson Ave. Self Madison, IN b7250

Elunier, Mary Lou 421 Mill St. Self Madison, IN 47250

Murphy, John W. Rural Route 3, Box 254 Jefferson Proving- Ground Lexington, IN 47138

Patterson, Nellie P.O. Box 702 Xadison Citizen State Madison, IN 17250 Employee

5 REGISTERED ATENDANCE AT PUBLIC MEETING HELD AT THE MADISON HIGH SCHOOL, MADISON, INDIANA ON 24 JWE 1991 CONCERNING BASE CLOSURE OF JEFFERSON PROVING GROUND

Organization Represented Name and Title Address or Subject of Interest

Perry, Bernard C. 6845 Mt. Vista Rd. U.S.Army TECOH Kingsville, MD 21087

Phillips, Cherry S. Route 113, Box 85 Self Vevay, IN 47043

Roberts, Ed Rural Route 2, Box 352 U.S.Army Lexington, IN 47138 JPG

Rogers, George R. 706 Buckingham Dr. U.S. Senator Richard Marion, IN 46952 Lugar

Robbins, Dan 725 S. Floyd WAVE-N Louisville, KY 40232

Sage, William H., Jr. 159 Parkview Dr. JPG Madison, IN 47250

Sage, William H., Sr. 435 Highland Drive Retired from JPG Madison, IN 47250

Scroggins, Grover 2835 Basswood Self Xadison, IN 47250

Smith, Donna I. 1915 Fairway Self Madison, IN 47250

Smith, Jerald R. Route 2, Box 35 Self Versailles, IN 47042

Smith, Phillip E. 1915 Fairway Dr. U.S. Army Madison, IN 47250

Stately, John F. 430 Bellaire Or. DAC Retired Madison, IN 47250

Strong, Yrs. Joel 1922 Van Buren Self Madison, IN 47250 . Torline, Xarie Rural Rouce 6, Box 28 Self Madison, IN 47250

Torline, Pat Route 6, Bpx 27 Self Madison, IN 47250

6 REGISTERED A'ITENDANCE AT PUBLIC MEETING HELD AT THE MADISON HIGH SCHOOL, MADISON, INDIANA ON 24 JUNE 1991 CONCERNING BASE CLOSURE OF JEFFERSON PROVING GROUND

Organization Represented Name and Ti2 Address or Subject of Interest

Torline, Paul E. Rural Route 6 Jefferson Proving Ground Madison, IN 47250

Vance, Wayne E. 1201 E. 10th St. 11107 Honorable Lee H, Hamilton Jeffersonville, IN 47130

Voris, Ray C. 1429 Bear St. JPG Madison, IN 47250

Wallace, John G. 1417 Crozier Ave. Self Madison, IN 47250

White, Pual 8. P.O. Box 192 JPG Madison, IN 47250

Wilkinson, Howard 617 Vine St. Cincinnati Enquirer Cincinnati, OH 45202

Williams, Larry Rural Route 7, Box 172 IN ANG Hadison, IN 47250

Wolfschlag, Bob 711 E. Main Self Madison, IN 47250

Golfschlag, Thomas J. 216 Hillcrest Dr. Self Madison, IN 47250 k'ood, Linda Rural Route 1 JPG Lexington, IN 47138

Wooden, Morris 804 Banta City of Madison Mayor Madison, IN 47250

Wycoff, Jack 502 Jefferson St. Self Madison, IN 47250 kycof f , Linda 502 Jefferson Sr. Self Madison, IN 47250

Yoncey, Harold Route 4 Self Madison, IN 47250

Zapp, Cathy 326 Goins Rd. Self Madison, IN 47250 YUMA PROVING GROUND COMMENTS AND RESPONSES YUMA PROVING GROUND COMMENTS AND RESPONSE CONCERNING THE DEIS

I AAS YUMAN ARCHAEOLOGICAL SOCIETY, LETTER OF JUNE 19,1991

1-1 As President of the Yuman Archaeological Society, a Chapter of the Arizona Archaeological Society. 1 want to express concern regarding the mitigation of impacts to Cultural resources resulting from disturbances by new consuuction and new operations at YPG, which are part of the mission transfer from JPG, Indiana.

As indicated in the Environmental Impact Assessment, the Archaeological Resources at YPG have not been fully surveyed and have knto even a lesser degree studied, inventoried, recorded, or evaluated paradoxically, the Military Operations at YPG while being a threat to existing resources there were also (over the years) the means to preserve Archaeological sites from normal inmsive damages, Le., mining and recreational desert users. The new expansion of activity at YPG will surely over-whelm sites which could significantly contribute to the cultural body of knowledge in Southwestern Arizona.

This Society is therefore concerned, that to the fullest extent, sites worthy of preservation are adequately protected and that sites which are destroyed be evaluated and studied to the degree necessary for all professional considerations.

RESPONSE: Through the completion of the cultural resource inventory coupled with compliance to the Memorandum of Agreement (Appendix C), these resources will either be protected or studied to the degree necessary for all professional considerations.

2 DEPARTMENT OF THE INTERIOR US. FISH AND WILDLIFE SERVICE, LETfER OF JUNE 20, 1991

2-1 The Kofa Firing Range, Main Administration Area and Mobility Test Area should be evaluated for wildlife and botanical values and suitable mitigation should be accomplished prior to the siting of any facility that would be part of this project.

RESPONSE: The report of biological surveys will not be complete until late 1991, and therefore, will not be part of this EIS. However, preliminary results of surveys conducted using the Army's land condition trend analysis methods indicate that biological impacts will be within or nearby areas previously disturbed by current YPG activities. Biological inputs are minimized by realigning the mission to previously disturbed areas at YPG. Once the biological surveys are. completed, any additional mitigation measures requid will be coordinated with the USFWS and the Arizona Department of Game and Fish.

2-2 New facilities should be located in areas of previous disturbance or in low quality habitats to minimize adverse effects. .

RESPONSE: New facilities are planned to be placed in or adjacent to areas of previous disturbances in order IO minimize adverse effects. YPG COMMENTS AND RESPONSES (continued)

2-3 No specific mitigation measures or commitments are described in this report and they should be developed and implemented prior to construction.

RESPONSE: Biological surveys are ongoing, and as such, detailed mitigation measures have not yet been developed. Project design has accomplished a considerable amount of mitigation by placing the facilities within or adjacent to disturbed mas. The greatest potential for biological impacts are to sensitive plant species. In the event that species m found during the surveys, coordination will be made with the USFWS to develop mitigation measures.

2-4 It would be useful to have one map in the document that shows the locations of both the existing facilities and the ones proposed under this realignment as the relationship between the two in the maps provided is not clear.

RESPONSE: Figure 2.4-2 provides a location of facilities relative to the existing facilities at YPG. New facilities will be located near or between existing facilities within the firing line ma.

2-5 The discussion of special status species in this document is confusing. We recommend defining the various terns reflecting status, doting which ones reflect a protected legal status.

RESPONSE: Section Y.3.1.8.1 has been changed to more clearly define the status of these species.

2-6 Please note in the table on page 3-98 that the Yuma puma is a Federal Category 2 species ;IS well as being State listed as endangered. This species should be addressed in the individual discussions of the sections of the YPG.

RESPONSE: Changes have ken made to appropriate sections.

2-7 On page 3-99, habitat of the desert tortoise is described as open desert scrub in anxs of deep soils. That description more correctly describes the Mojave population habitat preference rather than the Sonoran population habitat. In Arizona, slopes and bajadas are the preferred habitats for desert tortoise, with rocky areas used for dens and burrows.

RESPONSE: This change has been made to more correctly describe the habitat for the desert tortoise.

2-X On pages 3-100 and 3-102, under “Species of Concern,” the Yurn;i puma should be included.

HESI’ONSE: This subspecies is included under the species of concern section. YIW COMMENTS AND RESPONSES (continued)

2-9 We recommend that you contact our Kofa and Imperial National Wildlife Refuges to ensure their concerns are addressed in this realignment action. We have sent copies of the DEIS to them for their use.

RESPONSE We huve contacted these refuges during the preparation of the DEIS and no additional concerns were received.

3 ARIZONA STATE PARKS, LETTER OF JUNE 17,1991

3-1 Page 3-115 (and others) of the EA states that contractor’s recommendations are recognized as official eligibility statement by YFG. This statement is in reference to eligibility for the National Register of Historic Places and apparently was made by Tim Nowak, formerly with YE. The Army should never consider National Register eligibility assessments made by contractors as official. National Register eligibility determinations are made in consultation between the agency (Army) and the State Historic Preservation Officer (SHW). If there are disputes between these two, the Keeper of the Register may make a formal determination. Consultants sometimes do not make National Register evaluations and if they do, these are only recommendations for the agency. Consultants also make eligibility determinations that are not agreed to by the agency M SHPO. Therefore, we urge that you delete the reference to contractor’s making the eligibility determinations and ensure that the consultation is done through the proper parties.

RESPONSE: The Army is cumntly coordinating with the Arizona SHPO concerning rcsults of cultural resources inventory. Coordination will continue pursuant to the MOA.

3-2 For your infoxmation, Northland Research has recently completed an archaeological survey of the BRAC staging mas. The report is currently in draft form. Northland identified over 70 sites and even more isolated Occumnces (some of which should be sites). To date, no National Register determinations have been made based on this survey.

RESPONSE: See response to comment 1-3.

3-3 For the purposes of the EA, we believe the statement made in the middle of page 4-29 is adequate for administrative/compliance purposes.

RESPONSE: Comment noted.

4 ARIZONA CAME AND FISH DEPARTMENT, LETTER OF JUNE 28,1991

4-1 We find the Proposed Action, as outlined in Section 2.4.1 on page 2-18 of the DEIS, to be the most preferable of the Yuma Proving Ground based alternatives from a wildlife and wildlife habitat perspective. Y PG COMMENTS AND RESPONSES (continued)

RESPONSE: Comment noted.

4-2 We expressed concern during the scoping process about development of new facilities on the East Arm and concur with the statement in Section 2.4.2.1, on page 2-25, that "...use of the c:~Arm as a firing range would create significant impacts to plant and wildlife resources...."... We also concur that development of new facilities on the West Am as described in Section 2.4.3.1, on page 2-25, would result in significant impacts to Wildlife resources.

RESPONSE: Comment noted.

4-3 In general, we believe that any proposed use of depleted uranium @U) or potential hazardous materials should be carefully evaluated. Measures to protcct wildlife resources and the desert environment should be evaluated during the planning phase.

RESPONSE: The use of DU at YPG will continue in accordance with NRC requirements. Projectiles will be fired into specially constructed catchment facilities to recover DU. The cumnt Environmental Radiological Monitoring Plan (ERMP) will be amended to address the additional use of DU at YPG.

4-4 The analysis of impacts of the Proposed Action on traffic and transportation. Section Y.4.4.5.8 on page 4-36, should include evaluation of increased traffic on the animal collision problem along Highway 95. Vehicle collisions with large animals including horses, burros, and deer are common and increased traffic may exacerbate this problem. A study of the existing situation, including existing watering facilities, and proposed new developments, should be initiated. Questions regarding horses and burros on the area should be directed to the Bureau of Land Management, Yuma Dismct. Our Department can provide information on deer movements and offer suggestions.

RESPONSE: Section Y.4.4.5.8 has bcen revised to discuss the problem with vehicle collision with large animals. YPG will cooperate with the efforts of the BLM and other agencies regarding this problem.

5 DR. LOTHAR SCHMIDT,LETTER OF JUNE 29,1991

5-1 Added comments include: Not noting the one year tenure of Yuma County Administrator, Jlm Stahle. rather than the DRAFT EIS entry: Andrew Torres. RESPONSE: Comment noted. Mr. Torres, however, was the person from which we received thih information.

5-2 On pages 2-20 and 2-21 the ammunition-related facilities 6 and 8 are transposed.

RESPONSE: This correction has been made YPG COMMENTS AND RESPONSES (continued)

5-3 On page 2-20 and 2-21 the UKAF'I' proposes to add two direct fin: gun positions south of I'oleline Hd. During the working week Poleline Kd. is a heavily used corridor to support down riinge activity. The necessary speed limit and the length of the road combine to keep traffic on this urtery for hours. In the future event of traverse fire into say the DU or other select impact area. traffic cessation, reduced task performance and inmased radio traffic will follow. YPG hand held radios cannot operate at the more easterly reaches of Poleline Road. we often hear here: Is there a telephone near you?

Instead the reasoning for not siting these two gun positions to the presently non-existent gun positions near and beyond GS20 ought to be presented in the Final EIS.

Given the variables in acceptance testing the east-west direction for down range firing would seem to be preferable to the northly angles fire from the south of Poleline Rd.

The permissible impact area and safety would seem to avoid heavy caliber fre south of Poleline Rd. since there can be many variables in production ammunition testing. Aside from smoother range operations, keeping all JPG gun positions north of Poleline Rd. would help conserve the environment's habitat, wildlife and cultural features.

RESPONSE: Future range utilization apart from the proposed BRAC action was the basis for selecting the direct fire range south of Pole Line Road. Several alternatives were considered, and the proposed plan was selected based on future mission requirements, logistics, cost, range scheduling, and environmental factors.

5-4 YPG-wide environmental analyses and surveys in Spring 1991 included: soil, vegetation, small and large mammals, reptiles and birds. These extensive efforts under the LCTA program document the Army ability to manage its large environment and its resources. A specific reference to the Final EIS to these efforts is supported.

Page 3-93, the sentence beginning "Conspicuous species" does not concur with USFWS bird lists, five years of breeding bird urnsects at the Kofa NWR, or the LCTA bird surveys at YPG in the Spring 1991.

The commonest birds in the adjoining Kofa NWR bird species lists for three or more seasons of the year include White-winged and Mourning Doves, Phainopeplia, Verdin, House Finch and Gila Woodpecker. None of the DRAFT EIS's "conspicuous species" were observed on YPG among the 52 species logged in the Spring 1991.

Pages 3-96/3-97,Table 4.3.1-3YPG Sensitive Wildlife Species West Arm - The Desert Rosy Boa was seen along the Ehrenberg Rd. near Pete's Wash and North Trigo Peaks, May 20, 1991. Kofa Firing Range - three chestnut feral horses were observed along Firing Line Rd. near the Demo site, May 11. 1991. map coordinates 754XX N 3649XX E. YPG COMMENTS AND RESPONSES (continued)

West Arm - Several feral burros were worded along Middle Mountain Rd. and Rocket Alley in South Cicola, e.g. May 12, 1991. P. 3-101 Feral horses were logged near GS25 at Demo site on the Kofa Firing Range. (The YFG Environmental section data base keeps track of burro and horse sightings at YPG.)

Page 3-101 The sentence beginning "The most common avian species found in the creosote- txtillo association..." was not in concumnce with the YFG LCTA surveys. White-winged and mourning dove, and phainopepla were abundant, i.e. more than common for the YPG-wide Spring 1991 survey. Spring provides the most diverse and numerous species counts.

Page 3-104 The Main Post ana includes family housing with gardens, planted lawns, shade trees and along Laguna Dam Rd. a sewage bond. These waditionally bird-rich habitats provided the most diverse species lists at YPG. European starlings and great-tailed grackles were most numerous of species observed May 25 and 26 1991 during the five 20-minute LfXA bird surveys.

Appendix K The Spring 1991 LCTA bird census found species not shown as observed in the table pages K-8 to K-20. Only those additions found at the Proposed Action maKofa Firing Range are listed below. Added details arc available at YPG STEYP-ES-E.

p. K-10 Feral horse p. K-14 verdin p. K-15 gambel's quail p. K-17 greater roadrunner, gila woodpecker p. K- 18 ash-throated flycatcher, phainopepla p. K-20 curve-billed thrasher, western kingbird, white-winged dove, mourning dove.

RESPONSE: Comments noted. Appropriate changes have been made.

6 BUREAU OF LAND MANAGEMENT, YUMA DISTRICT OFFICE, LETTER OF JULY 3, 1991

6-1 Page 2-2: Middle of page, change sentence to read: "Yuma Proving Grounds are located in the southwestern comer of Arizona ..."

RESPONSE: This correction has been made.

6-2 Page 3-96: Wild (feral) horses and burros should not be listed under sensitive species. They art: not listed by the State of Arizona. the U.S. Fish and Wildlife Services, or the Bureau of Land Management. . YPG COMMENTS AND RESPONSES (continued)

HE:SPONSE: This correction has been made. They were included because they are managed by Federal law.

6-3 Page 4-23: The third paragraph on this page states that the exact degree of impact that the proposed action would have on wildlife cannot be determined until studies are complete. We hope that the survey results and associated impact analyses will be includcd in the Final Environmental Impact Statement.

RESPONSE: See response to comment 2-3.

6-4 Also. Kofa Game Refuge should be changed to read Kofa National Wildlife Refuge.

RESPONSE: Comment noted, the change has been made.

6-5 Page 4-26: Analyses of the results of the noise. studies cunently underway should include the impacts from increased noise levels upon aesthetics in the human environment and the recreational quality of experience in backcounuy areas (including refuges) in the ma of the Yuma Proving Grounds. The proposed increased activity on the Yuma Proving Grounds and its proximity to the recently designated Trigos Wilderness Area (immediately to the west) should necessitate an analysis of the affects of outside sights and sounds upon the naturalness of the wilderness area. One of the criteria for wilderness designation is the influence of outside sights and sounds present at the time, and the introduction of new or increased sights and sound from the Yuma Proving Grounds, of any magnitude, may be in conflict with the Bureau’s regulations for managing wilderness areas. The Bureau of Land Management operates an 11,400-acre long- term visitor area just south of Quartzite, Arizona, which receives considerable use, especially during winter months. Approximately 5,000 to 6,000 winter visitors amve in recreation vehicles for stays of up to 7 months. They come to enjoy the solitude and quiet desert experience. The affects of noise and concussions from the increased munitions and artillery testing upon these visitors, as well as the townspeople of Quartzsite, should be discussed.

RESPONSE: Section Y.4.3 has been modified to reflect the results of the noise study. The noise study concluded that no additional noise impacts would occur outside of the boundaries of YPG.

6-6 Page 4-46: The increase in the amount of traffic on Highway 95 is likely to cause an increase in the number of vehicle collisions with wild horses, burros, and desert mule deer. We fed that the U.S. Army should consider an may of mitigating measures to reduce this safety hiizard, including, but limited to:

1. Fencing both sides of Highway 95 between at least mile markers 42 and 55 or ideally, between markers 42 and 80. . YPG COMMENTS AND RESPONSES (continued)

2. Providing shuttle buses between Yuma and various work locations at Yuma Roving Grounds with incentives to use the program, such as pay parking for private vehicles.

RESPONSE: YPG will encourage and promote expanded use of the ride sharing and/or public transportation to reduce the number of additional trips on Highway 95. YPG shares the concern on traffic safety on the roadway including the increase in potential for vehicles striking large animals. The responsibility for fencing is unresolved, but YPG will cooperate with the BLM and other Federal, state and local agencies in further investigating this issue and will use its influence in implementing solutions to this issue.

6-7 We suggest that no new water sources for wildlife, wild horses, or burros be established at the new buildings and installations called for in the Referred Alternative, unless it is shown to be beneficial to wildlife and does not increase or create a safety hazard.

RESPONSE: No new water sources for wildlife are anticipated at these facilities. In the event that sources are found to be beneficial, YPG will coordinate with state and Federal .wildlife agencies prior to implementation.

7 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY, LETTER OF JULY 3, 1991

7-1 The Department has reviewed the referenced EIS document regarding possible increased hazardous waste risks or the introduction of new hazardous wastes to the facility. The Department's review indicates that the effect of the increase in activity at YPG will be primarily an increase in present waste streams as managed by existing base facilities.

RESPONSE: Comment noted.

7-2 The EIS states that the functions of JPG will become part of YPG's responsibility (Section 2.2. page 2-6). If no hazardous waste is to be transfemd to YPG as part of this nansfer of function, the EIS should specifically state that condition.

RESPONSE: Hazardous wastes at JPG will not be transferred to YPG. Section 2.2 has been revised accordingly.

7-3 It is expected that the total number of rounds fired at YPG will increase by up to 50% (Section Y.4.4.6,page 4-38). The effect this increase in activity will have on the cumnt bum disposal areas for Unexploded Ordinance (UXO) should be stated. Any risks that are different from the current explosives employed at YPG should be stated.

RESPONSE: The current RCRA Part B permit application will be modified if additional explosive wastes at YPG cannot be accommodated in the OB/OD capacity that has been specified in YPG's current permit application with EPA and the state. YPG COMMENTS AND RESPONSES (concluded)

7-4 What is the expected increase in air, soil or groundwater pollution from this increased activity 7

RESPONSE: Sections Y.4.1.4. Y.4.1.6.1, and Y.4.2 &scribe the anticipated impacts associated with soil, groundwater or air pollution. The impacts associated with the proposed action are considered not significant. See. revised Section Y.4.2.

7-5 The Nuclear Regulatory Commission (NRC) license for YPG will change (Section 2.4.1.3, page 2-22). The EIS should state the expected increase in the allowable quantity of low level radioactive DU to be present at the facility at any one time.

RESPONSE The current license possession limit is 100,OOO kg. The possession limit will be increased to accommodate the JPG workload. This increase in possession license limits will be driven by the work demand balanced against the enhanced recycle capability enabled by the possession catch facility.

7-6 The EIS should state that as facilities are designed and constructed for the new fuing range expansion at Kofa Firing Range (KFR) (Section 2.4.1.1, page 2-18) that ADEQ will be notified of any new waste streams and the method(s) of disposal and/or waste management.

RESPONSE This notification commitment has been placed in Section 2.4.1.1. YUMA PROVING GROUND RESPONSE TO PUBLIC MEETING COMMENTS June 19, 1991

I YUMA ECONOMIC DEVELOPMENT CORPORATION

1-1 And what I have seen so far in this process, 1 do not see that the impact to the environment is going to be. all that severe inasmuch as this is a restricted area in the first place. And so there is not much that can be done on site by any civilians. So the part of the impact I don’t think is going to create that much of a harm.

1 do not think also that it’s going to be that much of a problem with our wildlife. I, being a hunter for many years and would certainly want to preserve that, feel very dedicated to that. 1 personally do not see that that’s going to be much of an impact, As you indicated early, the major impact that we are going to see is going to be the highway and from the curve on out to YPG and I don’t think that’s something that can’t be overcome. So on behalf of YEDC, we would certainly favor the addition to this program.

RESPONSE: Comment noted, no response is required.

2 MICHAEL RAY HOSKA

2-1 The only question -- and I don’t really have a prepared comment to make. I welcome the increased work load at the Yuma Proving Grounds. The question is clarifying an article 1 read in the paper with the bringing of Jefferson Proving Ground work to the proving ground here, will there be an additional fund set aside for improvement of the highway from the curve out to the proving ground that we know of.

RESPONSE: The Army is not responsible for roadway improvements on Highway 95. Mitigation measures in the form of bus service or car pooling will be. encouraged to reduce the traffic generated on Highway 95 due to YPG activities. The Army shares your concern with safety on the roadway and will work with other involved agencies for roadway improvements.

3 ALINE COLLINS YUMAN ARCHAEOLOGICAL SOCIETY

3- 1 As president of the Yuman Amhaeological Society, a chapter of the Arizona Archaeological Stricty. 1 want to express concern regarding the mitigation of impact to cultural resources resulting from disturbances by new construction and new operations at YPG, which are part of the mission transfer from JPG, Indiana.

HISPONSE: See response to written comment 1-1.

3-2 As indicated in the environmental impact assessment, the archaeological resources at YPG II;IVC not been fully surveyed and have been to even a lesser degree studied, inventoried, recorded (11 cvnluated paradoxically. The military operations at YPG -- while being a threat to existing YPG RESPONSE TO PUBLIC MEETING COMMENTS (continued) resources -- there were also over the years the means to preserve archaeological sites from normal inuusive damages; Le., mining and recreational desert users.

The new expansion of activity at YPG will surely overwhelm sites which could significantly conmbute to the cultural body of knowledge in southwestem Arizona.

RESPONSE: See response to written comment 1-1.

3-3 This society is, therefore, concerned that to the fullest extent sites worthy of preservation are adequately protected and that sites which are destroyed be evaluated and studied to the degree necessary for all professional considerations.

RESPONSE: See response to written comment 1-1.

4 JOHN COLVIN

4-1 We do have an extreme limited amount of land in Yuma County that’s available for other than its specific use; like the military has and the Indian reservations, the wildlife refuges and so forth.

And the wilderness areas that have just been designated in the past six M seven months are practically off limits anyway. So I would encourage if additional lands is required because of the movement of JPG from Indiana out here, that they take a serious look at including some of the lands that have been designated as wilderness rather than to take other land that we do have available to us now because of limitation on it.

RESPONSE: The Army plans to construct facilities within areas already used for firing missions at YPG which will minimize impacting less disturbed areas.

4-2 Environmentally the most significant thing I can think of that might help in the transfer of these people from JPG out here to use at YPG and also the others that will be hired, would be encourage carpooling as much as possible so that -- because the energy and the sulfur oxides and all that.

RESPONSE: See response to written comment 6-6.

4-3 We sure have high percentage of unemployed people here in the Yuma area and it’s -- part of it is seasonal conditions. But in transferring those that wish to come from JPG, of course, give them first priority.., But the remaining jobs that aren’t filled by transfer, if you could possibly -- rather than import more bodies, if you could fine-tooth our unemployed ranks here in Yuma, it would certainly help our local economy and in more than ways than several. YPG RESPONSE TO PUBLIC MEETING COMMENTS (continued)

RESPONSE: The percentage of personnel that will transfer from JPG or come from other areas cannot be predicted to any degree of certainty. However, it is predicted that the Yuma area will experience a positive economic benefit from the proposed action.

5 CARY MEISTER, CHAIRMAN YUMA AUDUBON SOCIETY

5-1 What I have mostly is to say on hazardous waste and it appears to me from looking at this that there will be a significant increase in the amount of hazardous waste and risk of exposure resulting from these proposed actions. The proposal mentions depleted uranium storage, beryllium and a variety of chemicals, which are, of course, necessary to the mission of the military, but that doesn’t remove their toxic nature.

I’m left with a number of questions about how much more toxic waste, where is it going to be, where it is going to be disposed of. The EIS talks about a plan concerning disposal and storage. but I would feel much more competent to comment on the hazardous waste issue if I would see this plan.

Now, there is precedence for including such a plan within an EIS. The All American Pipeline Company built a pipeline to cany liquid petroleum and was required to include as part of its EIS a cleanup plan in the event that they would spill their petroleum into the Colorado River. So I would hope that in the final EIS or as things develop, that this plan will be developed as part of the public participation process so the public is fully aware of what is involved and so that they may also participate in insuring that public safety will be considered.

RESPONSE: YPG currently has hazardous material plans that are in compliance with all applicable environmental regulations. These plans have been coordinated with appropriate agencies within the area. They are available and on file at the installation; but, they are not appropriate to include in this document.

5-2 The EIS also mentions a probability of ammunition accidents, including accidents involving uranium and I do not feel reassured in reading this. It is admitted that this will happen or is likely to happen on page 441 of the EIS, paragraph 3, and 1 would like to see more attention in the EIS devoted to how you plan to avoid a serious accident with weapons that contain uranium.

RESPONSE: All ammunition including those containing depleted uranium will be transported following all safety rules and regulations of the Department of Defense and Department of Transportation.

5-3 Another issue involving safety is the tlaffic issue. U.S. 95 out to YPG is a very dangerous road until about 7 in the morning and after 3:30 in the afternoon. Because there is a memendous amount of traffic going to and from YPG. I used to work out there and part of the time 1 drove and purt of the time I took the bus. YPG RESPONSE TO PUBLIC MEETING COMMENTS (continued)

I don’t know if that bus service exists any more, but I hope it does. I known there were plans to eliminate it and it was never very popular there.

I think one of the ways that could address the increased traffic issue would be by providing -- making sure that there is bus service, encouraging people, developing incentives to take the bus and reducing incentives to drive people’s own private vehicles. Such as, for example, instituting parking charges for parking lots. There is no reason why all these people should get into little cars in the morning and drive out one to a car when they could be taking the bus and getting an extra half-hour sleep like 1 used to do or reading like I used to do when the lights worked.

So I hope you will look seriously into augmenting and improving the bus service at YPG.

RESPONSE: See response to written comment 6-6.

5-4 As far as the problem of contamination by weapons; again I wasn’t too clear from the EIS what the procedure is. But I would like to see periodic cleanups done rather than waiting until the closing of a base to do the cleanup and this would make it less of a monumental problem, which apparently you have at JPG now that you are closing down there. So don’t wait until closing to start doing cleanup. There’s been a problem because of disposal, I suppose.

RESPONSE: YPG maintains an on-going program of cleanup of ordnance contamination. Any ordnance contamination associated with the mission transfer will be cleaned up as funding resources become available.

5-5 Another pollution issue that the EIS mentions is that of particulates. There will be more dust as a result of these activities, more particulates in the air and I was rather discouraged to rend the statement on page 425. The attitude seemed to be that, well, this area already exceeds the standards for particulates. So why should we worry about a few more? So I hope you will address this issue in a more serious fashion. We do have a particulate problem. It’s our only air problem right now; so let’s improve our air rather than just saying, ”Well, too bad. It’s going to be a little bit worse.”

RESPONSE: The air quality impact discussion, Section 4.2, has been revised to include additional mitigation measures.

5-6 On the wildlife issue; the EIS -- even the EIS admits that there will be a significant noise impacts and one of the concerns about these noise impacts is on the adjacent Kofa National Wildlife Refuge. This refuge -- much of this refuge was just recently designated wilderness by Congress and I would hate to see extensive noise impacts in an area that has just become a wilderness. The two are contradictory. So I would hope that you will continue to address this issue and work with the refuge and other concerned people to reduce the affects of the noise. YPG RESPONSE TO PUBLIC MEETING COMMENTS (continued)

RESPONSE: Subsequent to the completion of the DEIS, a noise study was completed on the proposed action at YPG. This study concludes that no additional noise impacts to the Kofa National Wildlife Refuge will occur as a result of the YPG Mission.

5-7 As far as cultural resources are concerned, again the EIS admits that there will be significant impacts on cultural resources. And I hope you will work with the archaeological society and other concerned people to reduce these impacts.

The archaeological study of this area is still pretty much in its infancy. It’s an area that’s been largely overlooked by archaeologists because they wanted to get goodies; lots of pottery, lots of buildings. So they have concentrated more on other groups in the eastern Arizona. An similarly California archaeologists have tended to neglect this area and it’s only now that we are beginning to get a better understanding of the cultures of this area.

So to destroy archaeological sites at this point is -- it’s a very critical point in our knowledge of this area. So we need to give it very special attention.

RESPONSE: As described above, cultural resource surveys have been compleicd. See response to written comment 1-1. . 5-8 In terms of economic impact; one thing that I noticed in Table 2.2-1 “Caretaker Costs at Jefferson Proving Ground do not appear to be included in this table. And I think that this tends to obscure the costs involved in this whole process.

RESPONSE: See response to written comment 1-11. If a caretaker force is required, its size and function will be. determined. The size and function of the caretaker force has not yet been determined.

5-9 The other thing is we have heard a fair amount of mention tonight about over 250 jobs being created and, of course, some of these jobs will be taken by people transfemng from Jefferson. But I hope that this will not be ovcr-emphasized or be looked at in a over-optimistic way. How many of these jobs really will go to people in Yuma County. How many pple in Yuma will get these jobs. I think sometimes this factor is blown out of proportion when you Stan talking about multiplier effects. There is considerable literature in economics and sociology that does not accept the multiplier effects the level that some people use.

So I think you need to use caution there. Perhaps it’s not so much the Army that’s been proclaiming this as maybe some people locally.

RESPONSE: The extent of new jobs available for current residents of the Yuma area cannot be determined at this time. There will, however, be a net increase in employment-resulting in increased economic activity regardless of the degree of employment of current residents. Y PG RESPONSE TO PUBLIC MEETING COMMENTS (continued)

5-10 Finally, technical aspects of the EIS. The no-action alternative is listed as an alternative, but when I look at the economic or the environmental impact section, I find very little, if any, consideration given to the no-action alternative.

We don’t really get a view of what is going on at present to use as a baseline to determine how significant the changes will be. So I would like to see augmentation of the EIS’s no-action alternative.

Now, I realize that the no-action alternative is not a viable alternative under the constraints that you are working. But on the other hand, the no-action alternative is required by NEPA even if, in fact, it’s not what you are going to be doing.

When the Bureau of Land Management does a resource management plan, the no-action alternative is not a viable alternative for them either. They have to make some changes because of FLPMA. the Federal Land Policy and Management Act.

Nevertheless, they do write a considerable amount about the current situation so that you can assess the baseline effects.

1 am a little disappointed that the law was used to ovemde NEPA in that it has limited your choice of alternatives and that you can’t consider other areas for relocation. And while I realize that perhaps there is nothing you can do about it, I just wanted to express my disappointment that that was done in the law.

RESPONSE: The Army uses the Economic Information Forecast System (EIFS) to evaluate socioeconomic impacts of all base disclosures. The no-action alternative would result in the continuing of the current baseline. (See Section 3)

5-11 Now, Yuma has, 1 feel, provided more than its share of land and exposure for military activities. We have Yuma Roving Ground and we have Marine Corps Air Station. And given the fact that we will be looking at significant increases of exposure, storage, disposal of hazardous waste; I feel that maybe there comes a point when the people of Yuma need to say we have borne our mission as citizens in supporting the military proudly, but how much are we expected to take?

RESPONSE: Comment noted.

6 JIM URECK, DIRECTOR ARIZONA WILDLIFE FEDERATION

6-1 We at that time expressed a concern that the east arm alternative -- that that areahmain as it is now, open to the public. So we are happy to see that the south arm or the southern arm, thc Kola arm, has been chosen for this site. Y 1% RESPONSE TO PUBLIC MEETING COMMENTS (concluded)

RESPONSE: The current status of access to the East Arm of YPG will not be affected by the proposed BRAC action.

6-2 We also predicted back when they made the Kofas a wilderness that some people would express some problems with adjacent areas because they were next to a wilderness area.

RESPONSE: Comment noted.

7 ANN LEWIS, REGISTERED NURSE

7-1 I’m concerned about the potential -- I’m Concerned about the potential health impact; particularly as it relates to the transportation of hazardous materials and waste.

RESPONSE: YPG will follow all regulations and procedures covering handling and transportation of hazardous materials. (See response to public hearing comment 5-2.)

8 LUCY SHIPP COUNTY PLANNING AND ZONING CHAIRMAN

8-1 I don’t feel the need to speak except we are pleased with the expansion of YPG.

RESPONSE: Comment noted.

9 LINDA BENNETT REALTY EXECUTIVES

9-1 I’m from out in the Wellton area and 1 worked for the Town of Wellton for about five years and ever since that we have heard that this thing was coming out to that end of our valley, most of the people out there have been looking forward to it and we welcome you here and welcome the expansion.

RESPONSE: Comment noted. AAS YUMAN ARCHAEOLOGICAL SOCIETY P.O. BOX 5091 YUMA. AZ. 85366

U. S. Army Engineer District, Louisville ATTN: James M. Baker [CEORL-PD-R) P.O. Box 59 LOUISVILLE, KENTUCKY 40201-0059 Degr Sirs:

As ,President of the Yuman Archaeological Society, a Chapter of the Arizona Archaeological Society, I want to express concern regarding the mitigation of impacts to Cultural resources resulting'from disturbances by new construction and new operations at YPG, which are part of the mission transfer from JPG. Indiana.

A6 indicated in the Environmental Impact Assessment, the Archaeological resources at YPG have not been fully surveyed and, have been to even a lesser degree studied, inventoried, recorded, or evaluated paradoxically, the Military Operations at YP@while being a threat to existing resources there were also (over the years) the means to preserve Archaeological sites from,,normalintrusive damages, i.e., mining and recreational desert,users. The new expansion of activity at YPG will surely over-whelm sites which could significantly contribute to the cvltural body of knowledge in Southwestern Arizona.

This Society is therefore concerned, that to the fullest extent, sites worthy of preservation are adequately protected and that sitks Which are destroyed be evaluated and studied to the degree necessary for all professional considerations.

Sincerely.

hline Collins, P:resident UNITED STATES DEPARTMENT OF THE INTERIOR FISH AND WWFE 8ERvIQ ECOLOGICAL SERVICES 3616 W. %cas. Suite 6 Phoenix, Arizona 85019

June 20, 1991

Mobility Test Area should be evaluated for wildlife and botanical values and suitable mitigation should be accomplished prior to the siting of any 0 facility that would be part of this project. New facilities should be

It would be useful to have one map in the document that shows the locations @ of both the existing facilities and the ones proposed under this realignment as the relationship between the two in the maps provided is not clear.

Please note in the- table on page 3-98 that the Yuma puma is a Federal category 2 species as well as being State listed as endangered. This species should be addressed in the individual discussions of the sections of the. YPG.

On pa9e 3-99, habitpt of the desert tortoise is described as open desert srriib in areas of deep soils. That description more correctly describes the Moliave population habitat preference rather than the Sonoran population habitat. In Arizona, slopes and bajadas are the preferred habitats for desert tortoise, with rocky areas used for dens and burrows. a

On pages 3-100 and 3-102, under "Species of Concern," the Yurna puma should be included.

We recommend that you contact our Kofa and Imperial National Wildlife Refuges to ensure their concerns are addressed in this realignment action. We have sent copies of the DEIS to them for their use.

If we can be of further assistance, please contact Ms. Lesley Pitzpatrick or me (Telephone: 602/379-4720).

Siwerely,

Gilbert D. Met?/ Acting Field Supervisor ...... I' cc: Regional Director, Fish and Wildlife Service, Albuquerque, New Mexico (FWE/HC) and (WR/AZ-h") Director, Arizona Game and Fish Department, Phoenix, Arizona Refuge Manager, Kofa National Wildlife Refuge, Yuma, Arizona Refuge Manager, Imperial National Wildife Refuge, Martinez Lake, Arizona c4 June 17, 1991

US. Army Corps of Engineers Attn: CEORL-PD-R (Jim Baker) P.O. Box 59 Louisville, Kentucky 40201 -0059

RE: Yuma Proving Ground (YPG), Draft EA for the Closure of Jefferson Proving Ground, DOD-Army

Dear Mr. Baker:

Thank you for sending us a copy of the draft Environmental Assessment (EA) for the above project. I have reviewed those portions of the EA that PARKS apply to cultural resources in Arizona and have the following comments:

800 W. WASHINGTON 1. Page 3-1 15 (and others) of the EA states that contractor's SUITE 415 PHOENIX. ARIZONA 85007 recommendations are recognized as official eligibility statement by YPG. TELEPHONE 602-542-4171 This statement is in reference to eligibility for the National Register of Historic Places and apparently was made by Tim Nowak, formerly with YPG. The Army should never consider National Register eligibility assessments made by contractors as official. National Register eligibility determinations are made in consultation between the agency (Army) and the State Historic Preservation Officer (SHPO). If there are disputes between these Wo, the Keeper of the Register may make a formal determination. Consultants sometimes do not make National Register evaluations and if they do, these are only recommendations for the agency. Consultants also make eligibility determinations that are not agreed to by the agency or SHPO. Therefore, we urge that you delete the reference to WILLIAM G. ROE CHAIR contractor's making the eligibility determinations and ensure that the TUCSON I consultation is done through the proper parties. RONALD PIES 2. For your information, Norihland Research has recently completed an VICE cnm TEMPE archaeological survey of the BRAC staging areas. The reporl is currently in draft form. Northland identified over 70 sites and even more isolated DEAN M FLAKE occurrences (some of which should be sites). To date, no National SECRETAW SNOWFLAME Register determinations have been made based on this survey.

e Robert E. Gasser Compliance Coordinator KENNETH E. TRAVOUS EXECUllVf O(RECT0R lor Shereen Lerner. Ph.D. COURTLAND NELSON State Historic Preservation Officer MPUW URECTOR cc: Ken Ashworth. YPG

CONSERVING AND MANAGING IRIZOWS HISTORIC RACES. HETORIC SITES. AND RECREATIONAL. XENIC AND NATURAL AREAS 2221 WuiGrcenway Road. phoenix. Arii~na85023.2312 (602) 942-3000 DVrlO, LhwL Shdr D.py Dwmr hsW. Splding June 28, 1991

We find the Proposed Action, as outlined in Section 2.4.1 on page 2-18 of the DEIS, to be the most preferable of the Yuma Proving Ground based alternatives from a wildlife and wildlife habitat 0 perspective. ' We expressed concern during the scoping process about development of new facilities on the East Ann and concur with the statement in Section 2.4.2.1, on page 2-25, that "...use of the east Arm as a firing range would create significant impactsto plant and wildlife resources....". We also concur that development of new facilities on the West Arm as described in Section 2.4.3.1, on page 2-25, would result in significant impacts to wildlife resources. In general, we believe that any proposed use of depleted uranium or potentially hazardous materials should be carefully evaluated. Measures to protect wildlife resources and the desert environment 0. should be evaluated during the planning phase.

An Equal DpporNnily Agency

.- Mr. Robert F. Fuller 2 June 28, 1991

We appreciate the opportunity to review the DEIS and we will make ourselves available to assist with resolution of wildlife related issues, as needed. Siccerely,

David L. Walker Habitat hraluation Coordinator Habitat Branch WEW: wew cc: Herman Kast, Bureau of Land Management, Yuma Larry Voyles, Regional Supervisor, Region IV Arizona State Clearinghouse, A2 91-80-0020 Comments to UHAFT Environmental Impact Statement

I - Lqtroduction- Specif'ic additions to the Final EIS are presented to further describe the YPG environment at tne KofA Hanee for the Proposed Action. Primarily, the USk Construction Engineering Research Lauoratory nas supportea extensive soil, veqetation and wildlife analyses over tne whole of YPG's 1200 square miles. This valuable environmental descriotion was developed concurrently with the DRAFT EIS preparation. Added comments include: Not noting the one year tenure of Yuma County Administrator Jim Stahle, rather than the DRAFT €IS entry: Andrew Torres. On paees 2-20 and 2-21 the ammunition-related facilities @ and@ are transposed. USA reasoning to locate certain two direct fire positions south of Poleline Rd. rather than in the immense areas, say to the nortn of GS20. I1 - _--Proeosed ------Action On p. 2-20 and 2-21 The OHAFT proaoses to add two direct fire gun positions -----south of Poleline ad. lJuring.the working week Poleline Rd. is a heavily used corridor to support down ranqe activity, The necessary speed limit and the lenzth of the road combine to ueep traffic on this artery for hours. In tne future event of traverse .fire into say the i)U or other select impact area, traf:ic cessation, reduced task performance and increased

rHdio traffic will follow. YPti hand hela radios cannot

oner3tr at tile riore easter1.v reaches 01' ?oleline Hd. we often hear nere: Is is tnere a telephone near you? lnstead the reasoninz for not sitinn these two eun positions

tn the presently non-existent eun positions near and Sevond

.;520 OUTht tO..Drj presentea in the Final LIS. Ci..,en the variables in acceptance testin;! the ehst-west direction I'or down ranqe Firing would seen to be preferaole. to the nortnly anrzled fire frorn tne soutn of' toleline 3a.

'She persnis!;aole imiiact irea and safety would see;n to ;iVoiO hr.3v.i udlioer fire south of' Poleline Hd. since there

tr:Jn he many vdriar~lesin 3roduction amnunition testinz. Paye Two Comments to DRAFT EIS

Aside from smoother ranoe operations, keeping all JPG qun positions north of Poleline Hd. would helo conserve the environment's habitat, wildlife and cultural features. The the attached newspaper article supplements these viers.

As mentioned, F~E.2.4-1 VS. Fiq, 2.4-2 on paces 2-20 and 2-21 show facilities @ and@ transposed, 111 - ...... Environment Additions to ORAFT EIS YPG-ride environmental analyses and surveys in Spring 1991 included: soil, veqetation, small and larpe mammals, reptiles and birds. These extensive e!forts under the LCTA procram document the Army ability to to manaEe its larqe environment and its resources. A specific reference in the Final EIS to tnese efforts is supported.

0. 1-93 The sentence beqinninp. "Conspicioue species" does not concur with USF&WS bird lists, five years of hreedinq bird transectsat +.he ltof~ NWR, or the LCTA bird surveys at YPG

in tne Snrin.? 1991. The commonest birds in the ad,ioininc KofA NWR bird species lists for thcee or more seasons of the year include ulhite-winged and Kourninr: Doves, Phainopeolia, Verdin, House Finch and Gila Joodoecker. None of the DRAFT EIS's "conspicious species" werc observed on 'YPG amonr! the 52 species loyged in the Spring 1901.

I). ;1-96/3-97 Taole 4.3.1-3 YPG Sensitive #ildlife Species (-Jest Arm - The Uesert Rosy Boa was seen along tne Ehrenberg Hd. near Pete's 'uash and North Trigo Peaks, May 20, 1991. KofA I'irinE Hange- Three chestnur. feral horses were observeo blonc Firinc line Rd. near the Demo site, May 11, 1931, map coor.linates 75dXX N 3649XX E. &est Arm - Several feral burros were recoroed alon: iiiodle Vountain ad. and "nocket P.1le.v in South Cibols, e.?. ..lay 12, 1~31, r,.. (-101 Feral horses were loozed near i,S%S at Lemo site on t.he KO~A1:irin.7, ~ance. (?'he Y?G Environmental section oita Iiii!,e kcens track 01' 3urro dn!l hnrse siyhtinqs ;it YPI;.) .

,,. <-IO? 'Vhe sentence beninnin,: "'Cne iiiost ciirninon avian snecier Iounci in the creosote-octillo association . . . was not in concurrence with the YPG LCTh surveys. White-winced dnd 2 a o e 'r h ree Comments to DRAFT EIS

:~ndmourninr. dove, and phainopepla were abundant, i.e. more

i.han common for the YPG-wide Sprinq 1991 survey. Spring

:,rovidns the most diverse and numerous species counts,

?. 1-10.1 The Main Post area includes family housing with ,:;irdens, planted lawns, shade trees and alone Laguana iJam

l3d. a sewace oond. These traditionally bird-rich habitats provided the most diverse species lists at YPG. European starlinqs and qreat-tailed crackles were most numerous of .inecies observed ].lay 25 and 26 1991 during the five 29-minute LCTA bird surveys. Appendix K The Sprinq 1991 LCTA bird census found species not shown as observed in the table Dazes K-8 to K-20. Urily those additions found at the Proposed Action area

Xol'fi. Firing Hanze are listed oelow. Added details are aviilanle at YPG STEYP-ES-E.

U. K-10 Feral horse

71. K-14 verdin i'. !;-15 Xambel's quail n. %-17 zreater roadrunner, cila woodpecker

@. K-1H ash-throated flycatcher, pnainopepla p. X-20 curve-billed thrasher, western kin~bir.d,white-winxed

(10ve. mourninz dove. IV - Heview of LCTA Breedin.? Bird Survey at YPG - Spring 1991 ts - UVEHVIEW The results of a Spring breeding bird survey in' Arizona's Lower Colorado Valley subdivision of the Lower Sonoran life zone are presented. Fifty-five transects were walked included wildlife sites and Main Post sites at YPG. Additionally birds observed enroute to/from wildlife sites were recorded. For comparision two bird-rich desert scrub one mile transects were performed at the 50-year protected local KofA National Wildlife Refuge. Total species/families found in all locales were 52, with 28 at the formal YPG LCTA wildlife sites. Appendix A Lower Sonoran ecological units describes the habitats surveyed. Sites reached and censused were 41. An added 12 sites were rated based on similarity to nearby sites, page-size color photos of the ecological unit and the LCTA plot map forms. B - LAND CONDITION TREND ANALYSIS This program documents Army ability to manage its wildlife resources. Appendix B (August 1989) details the program. At YPG soil, vegetation, wildlife and related site data were being obtained at the time of the breeding bird survey.

C - METHODS LCTA Bird Survey Plot Summary forms were used at the height of the YPG bird breeding season as reviewed with USF&WS manager Milton Haderlie. Primarily a loose leaf notebook of PMF and photos of various aspects of the site were used to locate the wildlife sites. ~dditionallythe 15 minute topographic maps for YPG were employed. Coordination included LCTA team leaders, YPG range operations controllers and managers. Appendix c, Site Schema numbers the sites censused.

All birds hea,rd and/or seen within 200 meters of a 100 meter transect line during a 20 minute period were recorded. This serves as 0.5 km oval. An "average'# score is obtained,based on the number of each species observed divided by three. This becomes a measure of the time that the species is on site. These are cocalea Ior eacn species present on the site, to give a total for that site. Given the rate of census proeress it was directed that morning sites that had bird cover (i.e. trees, grasses) would provide a better data sample than desert pavement flats or afternoon census. Thus it was felt that more sites might be reached during the breedi.ng bird season with the budget set. YPG's immense size in relation to most other.~rmyfacilities was a significant factor in limiting this bird survey. (Site 183 on the Engressor Pass 15 minute map within the KofA NWR required well into the afternoon given three hours of about 7 mph driving.) 'The species are usually identified by using the first two letters of the Latin family and species names. This 1991 breeding bird survey included sites on or within eight miles of all thirteen 15 minute maps describing YPG's million acres. D - RESULTS 1) Transects at YPG Appendix D - Survey Summary forms contains all bird transects performed per LCTA project manual method at YPG: formal wildlife numbered sites plus local requests to census two promising traditional bird sites (sewage pond along Laguna Dam road near Main Post entrance kiosk and a residential street). Appendix E lists each species average totalled over all formal wildlife sites walked plus the other species observed outside that plot. Appendix E shows the seven most commonly found birds at YPG. The remaining 24 birds had averages from 0.33 to 2.6.

2) USF&WS transects - April 25 & 26 1991

L'SF&WS .AS been surveying six representative sites to measure the effect of prior cattle grazing. Continuing with this survey for the breeding bird season a one mile transect is walked at a rate to permit bird identification. The transects are 200 feet wide. This represents approximately twice the area of the 20 minute LCTA transect areas. These sites are in the Livingston Hills quadrangle of the KofA NWR. KofAR 1 and 2 required 2 and 3 hours respectively for census. KofAl is "desert scrub8', with dark varnish rock pavement: flat, interfluvial ridges separate minor washes or runnels. KofA2 is a rich sloped canyon typical of upland slopes. The De la Osa well is at the canyon end. USF&WS describes this Burro Canyon as an upland desert scrub habitat, a show piece for members of the Arizona Bird Committee. The reason for including the refuge census in this report stems from the fact YPG 's 1,000,000 acres may be seen as a "U", with this refuge seated within this "U" with its 660,000 acres. Historically, it was a refuge since 1939 and then treated as a wilderness for about a decade. The following pages describe the census for end of April. The impact may be reviewed with the LCTA census for this season's surveys. Thirteen added species not present. at 'YPG were observed. -3 r3

J By JOHN VAUGHN 50 miles northeast of Yuma. .’ the closure of W’G’s East Arm. a; Staff Writer Transporbtion planners say that: recreational area neighboring the , U.S. Highway 95, the two-lane1 testing site. route from Yuma to YPC. will‘ Those .issues. previously raised The U.S.Army‘s plans to move an become congested unless widened to wilh Army officials. are expected to ;,mmunition-testing program to handle increased automobile and surface anew Wednesday during a Yumn Proving Ground have raised military’ truck trflic generated by public hearing in Yuma. lingering concerns in Yuma about the project. The Army has set the hearing fur Possible side Ofthe pro- There are also concerns that ar- 7 p.m. at Chilton Inn. 300 E. 32nd JeCt. chaeologid sites such as Indian St.. to explain the testing mission to YPC would detonate bombs, trails and petroglyphs auld be sac. Yumans and sllow them tu com- sl~ellsand mines in tests on its Kofa rificed in the development of the ment on the draft environmental Firing Range, which borders the testing area. impact statement issued for the southern boundary of the Kofa Na- Moreover, outdoqr enthus.jasts project. tional Wildlife Refuge and lies about worry that the?*j&t &id lead to Jefferson Proving Ground near I

+ . Madison. Iid., has tested the na- the Kofa range. tion’s. war ammo since 1941. but congreeaionally approved plans call YPC spokesman Chuck Wullen- for closing the base and shifting john could not my how many of the operations to YPG over the next jobs will be available to Yuma-area four years. residents. since an undetermined The consolidation involves the number ofemployees of the Indiana construction of artillery’ and mortar base presumably will transfer to ranges. ammunition preparation Yuma. and storage buildings. and other fa- “What they don‘t fill twith trans, .cilitiea on the west end of the Kofa ferring workers) will be filled lei- Firing Range. IY.” Wullenjohn said. “I’d say the msjority will be hired locdlv. We’re The move is expected to bring 271 just figuring a lot of them won’t new civilian jobs to YPC and $82.2 million in conitruetionI projects on See YPG. Page 7 I 1

PROPOSED EXPANSIONS RAISE TONCERNS 7 Closure of

Indiana base to brinn Y?‘G new projects, jobs want to make the move.: mon to the Kofa Firing Flange, he The Indiana wmmunity has op- said. wsed the move not only because it "We know thev'll be there. we io- a major employer, but also just don't know ;here they are." because Congress has made no While conceding that some of the plans to remove hundreds of thou- trails and dwelling sites will likely clands of round. of undetonated be lost, he said he how the Army ammunition left on the 100- will preserve some in a "policy of square-mile testing ground. coexistence." And while Yuma mins from In- "It really gets down to attitude, . diana's economic loss, Yumans and you can't really control that," ' nonetheless are concerned about Johnson said. other ConcequeDCBs of, the move. The East Arm, he said. contains Highway B5 congestion IS one. petroglypha and is bisected by the I Highwiy traffic has grown historically si nificant Coca- heavier over the years, in part Maricona trail. 8he Halchidhoma

., bscauae~~~~~~~~ of the commutes of 1.600 Indiana, driven from Califoraia by YF'G employees from Yuma Lo work. intertribal warfare in the 1800s. said Robert Vaughan. executive took the mute to an eventual link- director of the Yuma Metropolitan up with the Maricopa Indians near Pwg,, present-day Gila Bend, he said. By th vea, the d&tronal271 According to the draft en- worhwill not add dramatically to vironmental impact statement, ' wugestion, said Vaughan, whose testing would be confined to the o*tion plans the area's Lrans- Kofa Firing Range, but Johnson - portation Improvement. said he fears that the Army muld What Hill be noticed will be the eventually expand operations to the additional automobiles plus the East Arm. i Anny transport trucks hauling ord- 'We expect that will happen. We nanw p the.ammunition te@g don't think this document is a com- misaion;Vaughancaid. " plete statement of what will happen . Pkns .u for the.ordnanceto be out there in the next 20 years." unloaded from tnim at Blaisdell While the East Arm is YPG prop- and then hu$kdnorth to YF'G. erty, it traditionally has bean open WG's bmnundew to campers. hunters and sightseers, rpmdinanAp e rtothe said Yuman Jim Breck, a board Y that widening of the member of .the Arizona Wildlife highway from Yuma to YF'G is Federation. "becoming increasingly vital to our Breck, also a member of the Yuma ad uate and safe transportation Valley Rod & Gun Club, said repre- ne%.** sentatives of outdoor organizations Vaughan said the YhfPO has ap- expect to appear Wednesday to urge plied to the state Transportation Army oficials not to~'dosc'offthe Boara for'funds to widen the .East Arm. highway. to a 68-foot, four-lane "It's pretty much an accesa issue width over a 16.6-milestretch from with us." he said. "There's just re- Blaindell to the proposed testing dynot a bt of wide-open space out site. there. where people can enjoy the The widening would cost an desert." estimated $22.4 million. or $1.36 Copies of the drah environmental million a de. impact staFment are ,nv&ble.for,, The board has not acted.on the .public review'& YPG's lib%& id YMPO'e application. which must its public affairs ofice. and at the compete 'against requested trans- Yuma library, 350 S. 3rd Ave. portation projects from around the The draft statement, an inch-, state. thick document, describes the Meanwhile, Boma Johnson. staff testing, explains potential en- archaeologist for the US. Bureau of vironmental impacts of the testing Land Management's Yuma ofice, and lists measures to minimize any says there are concertu the Army harmful erects. could set up the ammullltion testing Comments gathered Wednesday . site without regard for the area's will be used to finalize the state archaeological value. ment, which will then serve is a SpcciIidly, centuries-old Indian guide to Army oNiaals developing trails and dwelling are- are corn- the testing sire. United States Department of the Interior BUREAU OF LAND MANAGEMENT - YUMA DIS IXIC I OFFICk -I II 3150 WINSOK AVENUE YUMA. AKllONA R5365 IN iepw RUXE To. 1790 (050) July 3, 1991

Page 4-23: The third paragraph on this page states that the exact degree of impact that the proposed action would have on wildlife cannot be determined @ until studies are complete. We hope that the survey results and associated impact analyses will be included in the Final Environmental Impact Statement. 2 The Bureau of Land Management operates an 11,400-acre long-term visitor area just south of Quartzsite, Arizona, which receives considerable use, especially during winter months. Approximately 5,000 to 6,000 winter visitors arrive in recreation vehicles for stays of up to 7 months. They come to enjoy the solitude and quiet desert experience. The affects of noise and concussions from the increased munitions and artillery testing upon these visitors, as well as the townspeople of Quartzsite, should be discussed.

Pa8e 4-46: The increase in the amount of traffic on Bighway 95 is likely to cnuse nn increase in the number of vehicle collisions with wild horses, burros, and desert mule deer. We feel that the U.S. Army should consider an yay of mitigating measures to reduce this safety hazard, including, but not limited to:

1. Fencing both sides of Hiehway 95 between at least mile markers 42 and 55 or, ideally, between markers 42 Md 80.

2. Providing shuttle buses between Yuna and various vork locations at Yuma Proving Grounds with incentives to use the program, such as pay parking for private vehicles.

We suggest that no new water sources for wildlife, wild horses, or burros be established at the new buildings and installation# called for in the Preferred Alternative, unless it is shown to be beneficial to wildlife and does not increase or create a safety hazard.

We appreciate the opportunity to coment on this document. If we can be of further assistance, pleaee contact Dave Curtis at 602-726-6300.

Herman L. Kast District Manager . . ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY I’ll..!SY VIS(;TOS. COVERSOR EDWARD 2. FOX. DIRECTOR July 3, 1991 RPU091,355

The Department has reviewed the referenced EIS document regarding possible increased hazardous waste risks or the introduction of new hazardous wastes to the facilit . The Department’s re\ ew 0 indicates that the effect of the increase in activity at YPG will be prim anlry an increase in present waste streams as managed by existing base facilities. Specific comments regarding the review of the EIS are

1. The EIS states that the functions of JPG will become part of YPG’s responsibility (Sec. 2.2, pg 2- 6). If no hamdous waste is to be transferred to YPG as part of this transfer of function, the US 0 should specifically state that condition. 2. It is exgected that the total number of rounds fired at YPG will increase by up to 50% (Sec. 9 Y.4.4. , pg 4-38). The effect this increase in activity will have on the current bum disposal arm for Unexploded Ordinance (UXO)should be stated. Any risks that are different from the current explosives employed at YPG should be stated. What is the expected increase in air, soil, or groundwater pollution from this increased activity? 3. The Nuclear Regulatory Commission (NRC) license for YPG will change (Sec. 2.4.1.2, pg 2-22). The EIS should state the expected increase in the allowable quantity of low level radioactive Depleted Uranium @U) to be present at the facility at any one hme. 4. The EIS should state that as facilities are designed and constructed for the new firing mge @ expansion at Kofa Firing Range (KFR) (Sec. 2.4.1.1, pg 2-18) that ADEQ will be notified of any new waste streams and the method@) of disposaI andor waste management. 4

cc: Dan Marsin Sandra Eberhardt Don Atkinson Virgil Martinez Project File Reading File

The Dqmrmunl of Enrironmmr.l Qwlq u Ai Equal Opparlvniry Afirm~weAction Empmployrr.

Post Office Box 600 Phoenix. Arizona 85001-0600 Rrrvrlrd Poorr 1 2 3

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8 9 PUBLICMEETING 10 JUNE 19, 1991, 7:OO P.M. 11 12 13 LOCATION: CHILTON INN 300 E. 32ND STREET 14 YUMA, ARIZONA 85364 15 16

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CHRISTINE ANNE HARRINGTON COURT REPORTER 1 June 19, 1991 7:OO p.m. 2 3 PUBLIC MEETING 4 LT. COL. MIKE COLEMAN: Good evening, Ladies 5 and Gentlemen. I hope this is -- I don’t know if this 6 mike is working or not. Can you hear me in the back? 7 Okay. 0 I’m Lieutenant Colonel Mike Coleman, 9 Deputy Commander of Yuma Proving Ground. I would like 10 to welcome everybody to this evening‘s public meeting. 11 The purpose of the meeting is to receive 12 your comments on the draft Environmental Impact Statement, 13 which is two-fold; it covers the closure of Jefferson 14 Proving Ground, Indiana and its transfer of its mission 15 to Yuma Proving Ground, Arizona. 16 Couple of things I would like to clarify 17 before we get started from the Yuma Proving Ground point 18 of view. First thing to be very clear about: we at 19 Yuma Proving Ground are dedicated wholeheartedly to 20 protecting our area at Yuma Proving Ground environments.-1 21 and in every way we can. 22 As you all know, we have 1500 Some 23 employees out there. These are not aliens from another 2 4. world. These are citizens of Yuma and Arizona and the 25 most part. So we are very interested in how we .

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1 interface with the people in the surrounding area because 2 we all live here and are homeowners and participate in 3 this community as a whole. So that's the first thing. 4 The second thing I would like to point 5 out is some changes that may be in somebody's mind since 6 the last time we met and discussed this openly was I in 1989. There has been some changes that some of you 8 may not be aware of and I just want to make it very 9 clear so everybody understands exactly where.Jefferson 10 Proving Ground is now going to be located. 11 So to do that I will walk around this 12 map and there is another one located in the back here. 13 When last we talked, we talked about a 14 thing called Jeffersonville and the idea was to put it 15 on our eastern ann, the eastern end of our Kofa Firing 16 Range. That was located out in this area here. 17 Because of the military's draw down in 18 a lot of areas, the production of ammunition has been 19 reduced drastically than when we first started talking 20 about it. That and several other considerations has 21 over the years -- has caused us to re-look on where are 22 we going, to put this Jefferson, when it closes, in here. 23 The scope of the thing right now is

24 to move Jefferson in toto and intersperse it along Our 25 current firing front on our western edge. .

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1 So to orient you to kind of what this map 2 says; this yellow is nothing more than -- this is this 3 map that you are looking at. To orient you the green 4 line is Highway 95. This is that portion of Yuma Proving 5 Ground, which is our western sector. These blue dots, 6 the circles and these two boxes here are the ranges and 7 the new facilities, that 80 million dollars plus worth 8 of construction that we are going to build to support 9 Jefferson Proving Ground. 10 And as you notice, all of that is along 11 our current firing front and south Pole Line Road; for 12 you who are familiar with our area. 13 There is proposed right now no new areas 14 affected by Jefferson Proving Ground that we have not 15 already had firing into. Okay. So all we have got is 16 basically consolidated JPG and kind of overlaid it on top

1? of what we are currently -- what we are doing. 18 Now I hope that makes clear what we are 19 talking about now. So keep this in mind as we discuss 20 this this evening. 21 I would like to turn it over to Lieutenant 22 Colonel Craig Johnson, who is Deputy Commander of the 23 of the Corps. Corps of Engineers have been heavily 24 involved in this environmental impact study and 25 Craig and his folks will now explain to you .

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1 exactly what the purpose of this evening's meeting is and 2 get the responses back from you. So everybody will have 3 a say that it's up and above board as we go along on 4 this environmental impact study. As I said, we are 5 citizens of this community, we want your involvement 6 and your say that goes on with this environmental 7 impact study. So Colonel Craig. 8 LT. COL. CRAIG JOHNSON: Thanks, Mike. Good 9 evening, ladies and gentlemen. On behalf of ,Colonel 10 Chuck Thomas, Los Angeles District Commander, and 11 Lieutenant General Hatch, who is the Corps Commander 12 of Washington, D. C., and I would also like to welcome 13 you and taking part for what I will call a team 14 situation. Before we begin, I want to make an 15 important point that we feel that we are part of a team. 16 The team is Jefferson Proving Ground, the team of Yuma 17 Proving Ground. The team is the local surrounding 18 communities in Yuma, mc, any county, city or state or 19 federal official that has anything to do with or is 20 impacted by this realignment, we consider part Of our 21 team. 22 And those that I'm going to introduce 23 here in a minute is a part of the team that is putting 24 together the documentation for this realignment efforts 25 and are very concerned and are genuinely interested in

CHRISTINE ANNE HARRINGTON COURT REPORTER 1 in here that have already made that decision for us and 2 we have been working hard -- very hard at putting the task 3 at hand and make this come about. 4 Now, I'm going to get into this formal 5 presentation and we will get on with the business at 6 hand here. Your team is comprised of members from Army 7 agencies, from the Army Material Command, Los Angeles a District. The Louisville District Corps of Engineers, 9 by the way, is the lead district for this joint EIS 10 between Jefferson Proving Ground and Yuma Proving 11 Ground. And then the Yuma Proving Ground has got a 12 very heavy part of this from their staff in helping to 13 provide us the information that we needed to do the 14 proper evaluations. 15 I want to introduce some of these people 16 tonight so we can get an idea of what they look like. 17 They have got their name tags on and after our 18 presentations tonight, if you have any particular 19 questions in any of these particular areas, then they 20 will remain here for a few minutes after the 21 presentation and you will be able to visit with them. 22 I would likeato start off first with 23 Jim Baker from the Louisville District, the coordinator 24 of the total JPG-YPG EIS effort. That's Jim up here. 25 Ron Ganzfried sitting to his left; he

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1 is my main guy in Los Angeles District, who is putting 2 the environmental documentation for the Yuma portion 3 together and he has got a staff that supports him and he 4 has got a contractor that he has hired that helps him; 5 that's John Westermeier that is sitting here. And 6 then from our friends at the Army Material Command, 7 Major Renee O'Brien and representing that Amy Material 8 Command and she is visiting all of the public meetings 9 within AMC here and she stays on the road quite a bit. 10 From Yuma Proving Ground, key people 11 are Lance Vander Zyl, Director of Environment and Safety. 12 Paulette Sanders, Chief of the Environment Division. Bil 13 Meyer is the Chief of Plans and Analysis. Ken Ashworth 14 is an archeologist, Phil Ramsey is the NEPA specialist 15 and I will explain "NEPA" in a minute. 16 Ron Gage is the Director of Logistics. A1 17 Johnson -- not related -- is Director of Law Enforcement

18 and Security. Ken Price is Chief of the Munitions and ' 19 Weapons Division. 20 You can see we have got a very substantial 21 staff here with a lot of interest and concern on putting 22 a product out on the street'that -- with minimum impact 23 and with maximum efficiency. 24 Before we begin receiving your comments, 25 what I would like to do now is kind of cover with you

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1 the background of the Base Closure and Realignment Act 2 that came out in 1988 and was made law and commonly 3 referred to as BRAC One. Don't get this confused with 4 BRAC 91 that's on the street right now. BRAC One is 5 law and it's the one that was originally put out 6 in 1988 and the goal of the BRAC legislation was to I improve the efficiency of the installations within the 8 Department of Defense. The number of installations 9 that came out on that original BRAC One list was 133 10 installations, of which Jefferson Proving Ground is 11 going to close and we will realign into Yuma Proving 12 Ground. 13 Now, this legislation or this EIS was 14 prepared in accordance with the legislation as is 15 stipulated by also under the guidance of the National ' 16 Environmental Policy Act, which is NEPA, and the 17 other applicable federal and state environmental 18 laws, such as the Endangered Species Act and your 19 National Historic Pr.eservation Act. 20 And all legal requirements have been met 21 and are ongoing and any agency coordinations will 22 continue to insure proper compliance before and after 23 the realignment is completed. So you can be assured 24 that we will legally meet all the requirements.

25 However, under this particular .

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1 legislation we were asked to not -- not to focus on 2 three specific items as it pertains to this NEPA 3 documentation for this EIS. That is: one, that this 4 EIS can't have an alternative that says that this move 5 will not take place. We are not allowed to consider 6 any other military installations for the transfer of 7 JPG and that the scope of the documentation has to 0 pertain directly to the impacts of this BRAC One 9 movement and not take into account any ongoing actions 10 that the installation has going on at the present time 11 or what they have intending to come up in the future. 12 Any ongoing actions that they have now 13 that's outside of BRAC or any ongoing master plans issue 14 that they have will all have to meet their own 15 environmental documentation requirements before they 16 will proceed, if required. 17 Now I want to talk a little bit about 18 this EIS and some of you know we were here in June 19 of '09 to conduct a scoping meeting, which we mentioned 20 earlier. At that time we gathered some very valuable 21 information from you folks, our team members, the 22 public, the city, the state) the county and federal 23 officials, the Proving Ground staff and from any 24 other -- all other interested agencies that had an 25 interest in this EIS.

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1 Now we have analyzed that information on 2 the existing conditions and investigated potential impacts 3 on the socioeconomic, physical, biological, cultural, 4 archeological and historic resources during this, the

5 scoping process. We believe we have been responsive to 6 all those concerns that were brought out at the scoping 7 meeting and all other concerns that have been brought 8 up since then. 9 We found that the realignment action -- 10 that is, the transfer of 271 civilian personnel to YPG 11 and the construction of facilities to support the 12 transfer of the ammunition testing mission from JPG to 13 YPG will not significantly impact the biological, 14 physical or cultural resources at Yuma Proving Ground. 15 A great deal of study and analysis was 16 conducted in order to determine the environmental 17 impacts of the proposed BRAC action and to develop the 18 alternative that was least impacting while still 19 accommodating the JPG mission at Yuma Proving Ground. 20 Now that proposed action involves 21 intensifying the use of existing facilities and 22 integrating the location of new facilities within the 23 western portion of the Kofa Firing Range -- as Lieutenant 24 Coleman said -- where Yuma Proving Grounds test 25 intrastructure is currently located. Also the majority

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1 of firings will occur from the existing firing front into 2 existing impact areas. The use and status of the easte. 3 Kofa Firing Range and east arm of Yuma Proving Ground 4 will remain unchanged by this BRAC action. 5 As part of the selection process for the 6 proposed action, a full range of measures were considered 7 and incorporated to avoid or mitigate impacts to the 8 physical environment, biological, socioeconomic 9 environment and cultural resources. 10 We recognize that there will be some 11 impacts occurring with additional traffic, noise, 12 generation of hazardous materials and with the expanded 13 testing mission. That's common sense that that's 14 what is going to happen. But the installation will wor' 15 to minimize this and will be in compliance with all 16 applicable laws and it has with these particular 17 impacts. 18 Additionally, our analysis indicates 19 the beneficial socioeconomic impacts of another 271 20 jobs coming to the local area and the associated 21 financial benefits that comes along with it. 22 Now, I want to move into just briefly 23 the schedule. We plan to finish and publish the final 24 EIS in August and copies will be sent to the Yuma Public 25 Library, the Yuma Proving Ground Library and to all others

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1 that are interested. And I will tell you how that will 2 work in a minute. 3 When the final EIS is published, there 4 will be another 30-day public review period. We then 5 expect the Record of Decision to be signed sometime 6 in September. This Record of Decision -- or ROD -- is 7 sent to the Congress as a formal notice of environmental 8 compliance and commitment. This is recognized as the 9 last step in the BRAC planning process. 10 We cannot have any realignment activity, 11 construction or personnel moves to take place until that 12 Record of Decision is signed. 13 The record of this meeting is being 14 made -- as mentioned earlier -- and all of your comments 15 will be included in the final EIS. 16 Now, we welcome your comments. I encourage 17 them. We are here to listen, we are here to take note 18 and to address them in the final portion, which will be 19 coming out in August. 20 Now, some of you may prefer not to speak 21 tonight, but you want to make written comments. I would 22 like for you to take those and for sure make written 23 comments to us and have them provided to us by the 8th 24 of July. Now, in this handout that you picked up this 25 evening on your way in, gives an environmenta.1 summary

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1 of the statement and on the bottom of the first page is 2 an address to Mr. Jim Baker, who is the one we request 3 you send all your written comments to for us to address 4 in the final packet. 5 Now, anyone wanting a copy of the final 6 EIS may also request one from the Louisville office, I which will be Mr. Baker. 0 Now, I would like to -- I want to open 9 up the meeting here for your comments on the draft EIS. 10 Before I do, I ask that we remain focused on the 11 Draft EIS for the BRAC actions at Yuma Proving Ground 12 and not get sidetracked on to other issues. 13 When you first came in, you filled out 14 a card -- a number of you did, I believe -- and indicat 15 whether you would like to make a statement tonight. 16 When making a statement, please come forward to the 17 podium and state your name and any interest you may 18 represent. 19 But, first off, I would like to invite -- 20 if we have any political appointed or elected officials 21 in the group tonight, I would like them to come up first 22 and make any comments that they would like. 23 Okay. Moving right ahead. My first card 24 is from Mr. Larry Nelson, Yuma Economic Development 25 Corporation, Chairman of the Board and he wou1.d like to

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1 make a statement. So Mr. Nelson. 2 MR. NELSON: First of all, I am Larry Nelson, 0 3 Chairman of the Board of Yuma Economic Development 4 Corporation. And in speaking in behalf of YEDC, we would 5 first like to say that the Army has been an extremely 6 good partner to our community. They have been involved 7 in our community and are concerned about our community. 8 And what I have seen so far in this 9 process, I do not see that the impact to the environment 10 is going to be all that severe inasmuch as this is a 11 restricted area in the first place. And so there is not 12 much that can be done on sight by any civilians. So 13 that part of the impact I don't think is going to 14 create that much of a harm. 15 I do not think also that it's going to 16 be that much of a problem with our wildlife. I, 17 being a hunter for many years and would certainly want 18 to preserve that, feel very dedicated to that. I 19 personally do not see that that's going to be much Of 20 an impact. As you indicated early, the major 21 impact that we are going to see is going to be 22 the highway and from the curve on out to YPG and 23 I don!t think that's something that can't be 24 overcome. 25 But I certainly want to speak in behalf

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of YEDC and say we certainly would welcome this industry into this community. You have been a good industry and it's a high-tech industry. People are constantly saying they would like to see high-tech in Yuma, Arizona and we have high-tech in Yuma, Arizona at Yuma Proving Grounds right now. And a lot of people don't realize the technical abilities that there are out there as 8 well as the Marine Corps Air Station. So on behalf of YEDC, we would certainly favor the addition to this program. 11 LT. COL. JOHNSON: Thank you, sir. Next is 12 Mr. Michael Ray Hosko. 13 MR. HOSKO: My name is Michael Ray Hosko and@ -14.. -I just speak as a concerned citizen. The only questio.n--z. 15 and I don't really have a prepared comment to make. I 16 welcome the increased work load at the Yuma Proving @ 17 Grounds. The question is clarifying an article I 18 read in the paper with the bringing of Jefferson Proving 19 Ground work to the proving ground here, will there be 20 an additional fund set aside for improvement of the 21 highway from the curve out to the proving ground that 22 we know of. 23 LT. COL. JOHNSON: That's a good question, sir. 24 We will address that in the final portion. 25 MR. HOSKO: Okay. -

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1 LT. COL. JOHNSON: Thank you. Miss or Mister 2 Collins. I can't make out the first name. 3 MRS. COLLINS: Aline. 4 LT. COL. JOHNSON: She is from the Yuma 5 Archeological Society. 6 MRS. COLLINS: As president of the Yuma @ I Archeological Society, a chapter of the Arizona 0 Archeological Society, I want to express concern regarding 9 the mitigation of impact to cultural resources resulting 10 from disturbances by new construction and new operations 11 at YPG, which are part of the mission transfer from JPG,

12 Indiana. .3 As indicated in the environmental .4 impact assessment, the archeological resources at YPG have 15 not been fully surveyed and have been to even a lesser !6 degree studied, inventoried, recorded or evaluated 17 paradoxically. The military operations at YPG -- while !8 being a threat to existing resources -- there were !9 also over the years the means to presezve archeological 20 sites from normal intrusive damages; i.e., mining and 21 recreational desert users. 22 The new expansion of activity at YPG will 23 surely overwhelm sites which could significantly 24 contribute to the cultural body of knowledge in 25 southwestern Arizona. .

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1 This society is, therefore, concerned 2 that to the fullest extent sites worthy of preservation 3 are adequately protected and that sites which are 4 destroyed be evaluated and studied to the degree 5 necessary for all professional considerations. 6 Aline Collins, president. 7 LT. COL. JOHNSON: Those are very good 8 comments. Thank you, ma'am. -& 9 John Colvi+&e, retired. clr 10 MR. COLVIhIR: Thank you, Colonel. I am just0 4 11 going to make some brief comments and I don't have any 12 prepared remarks. But we do have an extreme limited 13 amount of land in Yuma County that's available for 14 other than its specific use; like the military has and 15 the Indian reservations, the wildlife refuges and so 16 forth. 17 And the wilderness areas that have just 18 been designated in the past six or seven months are 19 practically off limits anyway. So I would encourage if 20 additional lands is required because of the movement 21 of JPG from Indiana out here, that they take a serious 22 look at including some of the lands that have been 23 designated as wilderness rather than to take other land 24 that we do have available to us now because of limitation 25 on it.

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1 Environmentally the most significant thing 2 I can think of that might help in the transfer of these 3 people from JPG out here to use at YPG and also the 4 others that will be hired, would be encourage carpooling 5 as much as possible so that -- because the energy and the 6 sulfer oxides and all that. I The final thing that I would like to touch 8 on -- it may not be specifically tied to the 9 environment -- but we sure have a high percentage of 10 unemployed people here in the Yuma area and it's -- 11 part of it is seasonal conditions. But in transferring 12 those that wish to come from JPG, of course, give them 13 first priority. But the remaining jobs that aren't filled 14 by transfer, if you could possibly -- rather than import 15 . more bodies, if you could fine-tooth our unemployed ranks 16 here in Yuma, it would certainly help our local economy 17 and in more than ways than several. 18 And I think my address is there, if you 19 have any questions, I would be glad to address them. 20 LT. COL. JOHNSON: Thank you, John. 21 Cary Meister. I hope I did pronounce 22 that right. Yuma Audobon Society Conservation Chairman. 23 MR. MEISTER: My name, indeed, is Cary 0 24 Meister and I occupy'the position that you mentioned

25 and I'm speaking on behalf of the Yuma Audobon~ Society.

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1 I have not had a chance to read through 2 the whole EIS, but I have had a chance to skim it. So 3 my comments tonight will reflect that level of 4 understanding and I will be submitting written comments 5 later on. 6 Our comments on this proposal center on 7 several areas. One of them is hazardous waste and 0 activities connected with it. Another is wildlife and '9 especially the effects of noise. The third jls cultural 10 resources. The fourth is economic impacts and a fifth 11 is technical criteria of -- required of an environmental 12 impact statement. What I have mostly is to say on 13 hazardous waste and it appears to me from looking at this 14 that there will be a significant increase in the amount 15 hazardous waste and risk of exposure resulting from 16 this proposed action. The proposal mentions depleted 17 uranium storage, beryllium and a variety of chemicals, 18 which are, of course, necessary to the mission of the 19 military, but, that doesn't remove their toxic nature. 20 I'm left with a number of questions 21 about how much more toxic waste, where is it going to 22 be, where is it going to be'disposed of. The EIS

I23 talks ,about a plan concerning disposal and storage, 24 but I would feel much more competent to comment on 25 the hazardous waste issue if I would see this plan.

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1 Now, there is precedence for including 2 .such a plan within an EIS. The All American Pipeline 3 Company built a pipeline to carry liquid petroleum and 4 was required to include as part of its EIS a cleanup 5 plan in the event that they would spill their petroleum 6 into the Colorado River. So I would hope that in the 7 final EIS or as things develop, that this plan will be 8 developed as part of the public participation process 9 So the public is fully aware of what is involved 10 and so that they may also participate in insuring 11 that public safety will be considered. 12 The EIS also mentions a probability of 13 ammunition accidents, including accidents involving 14 uranium and I do not feel reassured in reading this. It 15 is admitted that this will happen or is likely to happen 16 on page 441 of the EIS, paragraph 3, and I would like to 17 see more attention in the EIS devoted to how you plan 18 to avoid a serious accident with weapons that contain 19 uranium. 20 Another issue involving safety is the 21 traffic issue. U.S. 95 out to YPG is a very dangerous 22 road until about I in the morning and after 3:30 in the 23 afternoon. Because there is a tremendous amount of 24 traffic going to and from YPG. I used to work out there 25 and part of the time I drove and part of the-time I

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1 took the bus. 2 I don't know if that bus service exists 3 any more, but I hope it does. I know there were plans to 4 eliminate it and it was never very popular there. 5 I think one of the ways that you could 6 address the increased traffic issue would be by 7 providing -- making sure that there is bus service, 8 encouraging people, developing incentives to take the 9 bus and reducing incentives to drive people'.s own 10 private vehicles. Such as, for example, instituting 11 parking charges for parking lots. There is no reason 12 why all theee people should get into little cars in 13 the morning and drive out one to a car when they could 14 be taking the bus and getting an extra half hour sleep 15 like I used to do or reading like I used to do when the 16 lights worked. 17 So I hope you will look seriously into 18 augmenting and improving the bus service at YPG. 19 As far as the problem of contamination 20 by weapons; again I wasn't too clear from the EIS what 21 the procedure is. But I would like to see periodic 22 cleanups done rather than whiting until the closing of 23 a base to do the cleanup and this would make it less 24 of a monumental problem, which apparently you have at 25 JPG now that you are closing down there. So don't wait

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0 1 until closing to start doing cleanup. There's been a (cant.) 1 2 problem becomes of disposal, I suppose. Another pollution 3 pollution issue that the EIS mentions is that of 4 particulates. There will be more dust as a result of 5 these activities, more particulates in the air and I was 6 rather discouraged to read the statement on page 425. The @I 7 attitude seemed to be that, well, this area already 8 exceeds the standards for particulates. So why should 9 we worry about a few more? So I hope you will address 10- this issue in a more serious fashion. We do have a 11 particulate problem. It's our only air problem right now; 12 so let's improve our air rather than just saying, "Well, 13 too bad. It's going to be a little bit worse." 14 On the wildlife issue; the EIS -- even 15 the EIS admits that there will be significant noise 16 impacts and one of the concerns about these noise 17 ?$:,:.acts is on the adjacent Kofa National Wildlife Refuge. 8 18 This refuge -- much of this refuge was just recently ~ 19 designated wilderness by Congress and I would hate to

~ 20 see extensive noise impacts in an area that has just 21 become a wilderness. The two are contradictory. So I would hope that you will continue to address this ~ 22 23 issuetandwork with the refuge and other concerned 24 people to reduce the affects of the noise. As far as cultural resources are 0'I 25

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:- 1 concerned, again the EIS admits that there will be 2 significant impacts on cultural resources. And I hope 3 you will work with the archeological society and other 4 concerned people to reduce these impacts. 5 The archeological study of this area is 0 6 still pretty much in its infancy. It's an area that's (cod..) 7 been largely overlooked by archeologists because they 8 wanted to get goodies; lots of pottery, lots of 9 buildings. So they have concentrated more on other 10 groups in the eastern Arizona. And similarly California 11 archeologists have tended to neglect this area and it's 12 only now that we are beginning to get a better 13 understanding of the cultures of this area.

14 So to destroy archeological sites at thiF 15 point is -- it's a very critical point in our knowledge 16 of this area. So we need to give it very special 17 attention. 18 In terms of economic impacts; one thing 19 that I noticed in Table 221 "Caretaker Costs at Jefferson 20 Proving Ground" do not appear to be included in this 21 table. And I think that this tends to obscure the 22 costs involved in this whole process. 23 If I'm wrong, please correct me, but I 24 couldn't find that in the table. The other thing is we have heard a fair .

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1 amount of mention tonight about over 250 jobs being 2 created and, of course, some of these jobs will be taken 3 by people transferring from Jefferson. But I hope that 4 this will not be over-emphasized or be looked at in a 5 over-optimistic way. How many of these jobs really will 6 go to people in Yuma County. How many people in Yuma 7 will get these jobs. I think sometimes this factor is 8 blown out of proportion when you start talking about 9 multiplier effects. There is considerable literature 10 in economics and SOCiOlOgy that does not accept 1l the multiplier effects the level that some people use. 12 So I think you need to use caution 13 there. Perhaps it's not so much the Army that's been 14 proclaiming this as maybe some people locally. 15 Finally, technical aspects of the EIS. 16 The no-action alternative is listed as an alternative, 17 but when I look at the economic or the environmental 18 impact section, I find very little, if any, consideration 19 given to the no-action alternative. 20 We don't really get a view of what is 21 going on at present to use as a base line to determine 22 how significant the changesowillbe. So I would like 23 to see augmentation of the EIS's no-action alternative. 24 Now, I realize that the no-action 25 alternative is not a viable alternative under the

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1 constraints that you are working. But on the other hand, 2 the no-action alternative is required by NEPA even if, 3 in fact, it's not what you are going to be doing. 4; When the Bureau of Land Management does a 5 resource management plan, the no-action alternative is @\ 6 not a viable alternative for them either. They have to (con+, i 7 make some changes because of FLPMA, the Federal Land 8 Policy and Management Act. 9 Nevertheless, they do write a considerable 10 amount about the current situation so that you can assess 11 the base line effects. 12 I am a little disappointed that the law 13 was used to override NEPA in that it has limited your 14 choice of alternatives and that you can't consider othr 15 areas for relocation. And while I realize that perhaps 16 there is nothing you can do about it, I just wanted 17 to express my disappointment that that was done in the 18 law. 19 Now, Yuma has, I feel, provided more 20 than its share of land and exposure for military 21 activities. We have Yuma Proving Ground and we have 22 Marine Corps Air Station. find given the fact that we 23 will be looking at significant increases of exposure, 24 storage, disposal of hazardous waste; I feel that maybe

25 there comes a point when the people of Yuma need. to say

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we have borne our mission as citizens in supporting the (cod) 2 military proudly, but how much are we expected to take? 3 Thank you. 4 LT. COL. JOHNSON: Thank you very much. 5 Mr. Jim Breck from the Arizona Wildlife 6 Federation; he serves as its Director. 7 MR. BRECK: Ladies and gentlemen, my name is 6 8 Jim Breck. We commented on the scoping process 9 originally when that was held here in Yuma some time 10 back . 11 We at that time expressed a concern that 12 the east arm alternative -- that that area remain as it @ l3 is now, open to the public. So we are happy to see that 14 the south arm or the southern arm, the Kofa arm, has 15 been chosen for this site. 16 We do agree with some of the environmental 17 statements made by Mr. Meister. We have to be very 18 careful about some of the impacts that we might see and 19 their impacts on wildlife. 20 We also predicted back when they made 21 the Kofas a wilderness that some people would express 0 22 some problems with adjacent'areas because they were next 23 to a wilderness area. 24 So that being the case; that's all I 25 have to say. .

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LT. COL. JOHNSON: Thank you, sir. Antonia Flores, Arizona State Parks Site Steward Program, Region One Coordinator. She left a question mark. She changed her mind. Still here? Okay. Larry Knight, he made a question mark, from Yuma Valley Rod and Gun Club. Kenneth Ashworth, U. S. Army Proving Grounds. You don't want to make a statement? MR. ASHWORTH: No. I must have got in the wrong pile. LT. COL. JOHNSON: And Ann -- I'm sorry, this is either Lewis or Linoes. Lewis, maybe. c MS. LEWIS: I'm Ann Lewis and I'm a registere -I 15 nurse in Yuma and I'm concerned about the potential -- I'm concerned about the potential health impact; 0 :: particularly as it relates to the transportation of 18 hazardous materials and waste. I haven't had a chance to read the full EIS statement, but I plan to do that and address any more comments I might have from that in writing. LT. COL. JOHNSON:' Okay. Thank you very much. Lucy Shipp had a question mark; Yuma County Planning and Zoning Chairman. .

CHRISTINE ANNE HARRINGTON COURT REPORTER 29

1 MS. SHIPP: I don’t feel the need to speak 0f 02except we are pleased with the expansion of YPG and I just wanted to stay on top of what was going on. LT. COL. JOHNSON: Thank you very much. John Vaughn from the Yuma Daily Sun. MR. VAUGHN: No, sir. LT. COL. JOHNSON: Okay. Linda Bennett, Realty Executives, maybe. 9 MS. BENNETT: Yes. I’m from out in the 8 10 Wellton area and I worked for the Town of Wellton for 11 abwt five years and ever since that we have heard @ l2 that this thing was coming out to that end of our 13 valley, most of the people out there have been looking 14 forward to it and we welcome you here and welcome the 15 expansion. Thank you. LT. COL. JOHNSON: Thank you very much. Okay. That completes my cards. Do I have anybody else that is -- during the session here that thought of any questions or comments that they would like to present at this time? Well, if there aren’t any more comments at this time, I want to remPnd all of you to send your written comments -- have you got another card? MS. CLARK: No, I don’t have any. I just want to make sure everybody signed up and that everybody whose

CHRISTINE ANNE HARRINGTON COURT REPORTER 30

1 names I can't read. 2 LT. COL. JOHNSON: I would like to remind you 3 that Mr. Baker here and his address is on that first page 4 in that executive summary and to send your written 5 comments to him and also if you want to request a final 6 EIS, you can do that also. 7 We are now closing the formal meeting ana 8 our representatives will remain here for a while, if any 9 of you would like to discuss your concerns further. 10 Thank you very much for coming. 11 (Thereupon, that completes the public 12 meeting. )

CHRISTINE ANNE HARRINGTON COURT REPORTER 31

1 STATE OF ARIZONA 1 ) 6s: 2 County of Yuma 3 4 BE IT KNOWN THAT the foregoing hearing was 5 taken before me CHRISTINE ANNE HARRINGTON, a Notary Public 6 in and for the County of Yuma, State of Arizona; that 7 the statements thereto were taken down by me in 0 shorthand and thereafter reduced to typewriting under my 9 direction; that the foregoing 30-pages are-a'true and 10 correct taking of the said hearing, all done to the 11 best of my skill and ability. 12 I FURTHER CERTIFY that I am in no way related 13 to any of the parties hereto nor am I in any wise 14 interested in the outcome hereof. 15 DATED AT Yuma, Arizona this Jzfhday of 16 June 1991. 17 18 19 20 My Commission Expires: I\w dd./99+ 21 22 23 24 25