us EPA RECORDS CENTER REGION 5

480188

RECORD OF DECISION SITE 32 - NATIONAL GUARD PISTOL RANGE SAVANNA ARMY DEPOT ACTIVITY, SAVANNA, ILLINOIS

Prepared for:

U.S. Army Corps of Engineers Louisville District 600 Dr. M.L. King Jr. PI. Louisville, KY 40202-2232

Contract No. W912QR-04-D-0036 Task Order No. 0018

Prepared bv: EQ

Environmental Quality Management, Inc. 1800 Carillon Boulevard Cincinnati, Ohio 45240 (800) 229-7495 www.eqm.com

EQ FN: 030240.0018

June 2014 Site 32 - National Guard Pistol Range Record of Decision EQ Environmental Quality Management, Inc. June 2014

Sunii'

CONTENTS

Section Page Technical Review Certification v 1. Declaration 1 1.1 Site Name and Location 1 1.2 Statement of Basis and Purpose 1 1.3 Deseription of Selected Remedy 1 1.4 Statutory Determin ations 2 1.5 Authorizing Signatures 2 2. Decision Summary 3 2.1 Site Name, Location, and Description 3 2.2 Site History and Enforcement Activities 5 2.3 Community Participation 6 2.4 Scope and Role of Operable Unit or Response Action 6 2.5 Site Characteristics 7 2.5.1 Topography and Surface Features 7 2.5.2 Geology 7 2.5.3 Hydrogeology 7 2.5.4 Nature and Extent of Contamination 8 2.5.4.1 Surface and Subsurface Soil 8 2.5.4.2 Groundwater 9 2.6 Current and Potential Future Site and Resource Uses 10 2.7 Site Risks 10 2.7.1 Human Health Risks 11 2.7.2 Ecologieal Risk Assessment 11 2.7.3 Conclusion 12 2.8 Documentation of Significant Changes 12 3. Responsiveness Summary 13 3.1 Overview 13 3.2 Background on Community Involvement 13 3.3 Site Characteristies 14 3.4 Key Issue 14 3.5 Summary of Comments Received and Army Responses 15 3.6 Housekeeping Action 16 4. References 17

11 Site 32 - National Guard Pistol Range Record of Decision EQ Environmental Quality Management, Inc. June 2014

ATTACHMENTS

Attachment A Public Meeting Transcript, May 31, 2012 Attachment B Written Comments - IE?A Attachment C Written Comments - USFWS Attachment D Written Comments - RAB Attachment E Army Response to lEPA Attachment F Housekeeping Action Completion Report

FIGURES

No. Page

Figure 1. View of Savanna Army Depot 3 Figure 2. Installation Map with Site 32 and various other site locations 4 Figure 3. Site 32 View of Embankment 5 Figure 4. Site 32 RI - Soil Sampling Points 9 w

TABLES

No. Page

Table 1. Metal Constituents Detected in Surface and Subsurface Soil 8 Table 2. SVDA Site 32 - Metal and Non-Metal Constituents Detected in Groundwater 10 Table 3. SVDA Site 32 - Risk Assessment 11

111 Site 32 - National Guard Pistol Range Record of Decision EQ Environmental Quality Management, Inc. June 2014

ACRONYMS AND ABBREVIATIONS

APE Ammunition Peculiar Equipment AR Administrative Record Army United States Department of Army BCT BRAG cleanup team bgs below ground surface bis below land surface BRAG Base Realignment and Closure CERCLA Comprehensive Environmental Response, Compensation, and Liability Act COPC Chemical of Potential Concern DoD Department of Defense EPA Environmental Protection Agency EQM Environmental Quality Management, Inc. EPA federal facility agreement HA Housekeeping Action lEPA Illinois Environmental Protection Agency IR information repository mg/kg milligram per kilogram mg/L milligram per liter pg/L microgram per liter MOA memorandum of agreement NA Not Available NCP National Contingency Plan NPL National Priorities List PBT persistent, bioaccumulative, and toxic RAB Restoration Advisory Board RI Remedial Investigation ROD Record of Decision SAIC Science Applications International Corporation SARA Superfund Amendments and Reauthorization Act SI Site Investigation SVDA Savanna Army Depot Activity TACO Tiered Approach to Corrective Action Objectives U.S. United States USAGE United States Army Corps of Engineers USEPA United States Environmental Protection Agency USFWS United States Fish and Wildlife Service VOC Volatile Organic Compound

IV Site 32 - National Guard Pistol Range Record of Decision J-A^ Environmental Quality Management, Inc. June 2014

TECHNICAL REVIEW CERTIFICATION

Contract No. W912QR-04-D-0036 Task Order No. 0018

I certify that this submittal has been reviewed in detail and is correct and in conformance with the contract Performance Work Statement, dated 22 March 2010 and revised 21 June 2013.

QicJzo 5JUN14 Jackiede Doan, CQM, CQA, CEAC, CHMM, Contractor QA Manager Date

_ 5JUN14 Jame^ G. Zody, P.E., Program M^ger Date Site 32 - National Guard Pistol Range Record of Decision -£-A^ EnviromnentaJ Quality Management, Inc. June 2014

1. DECLARATION

This declaration provides an abstract of the key infonnation in the Record of Decision (ROD) for Site 32.

1.1 Site Name and Location

Site 32, otherwise known as the National Guard Pistol Range, is located at the Savanna Army Depot Activity (SVDA) in Jo Daviess County, Illinois. The United States Environmental Protection Agency's (USEPA) identification number for the SVDA is rL3210020803. c 1.2 Statement of Basis and Purpose This decision document for Site 32 at SVDA presents the selected remedy, as proposed by the U.S. Army (Aimy) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfimd Amendments and Reauthorization Act of 1986 (SARA), which requires the issuance of decision documents for remedial actions taken pursuant to Sections 104,106,120, and 122. Sections 300.430 (f)(2), 300.430 (f)(4), and 300.435(c)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) established the regulatory requirements for this decision document This decision is based on the Administrative Record (AR) for this site and is made by USEPA and the Army in consultation with the Illinois Environmental Protection Agency (lEPA).

13 Description of Selected Remedy

No CERCLA action is necessary for Site 32. Site 32 presents no unacceptable exposure to hazardous substances. The Army removed residual lead bullets, slugs, and shot fi-om the site in December 2013 as a Housekeeping Action (HA). The lead bullets, slugs and shot and associated w Site 32 - National Guard Pistol Range Record of Decision Environmental Quality Management, Inc. June 2014

1. DECLARATION

This declaration provides an abstract of the key information in the Record of Decision (ROD) for Site 32.

1.1 Site Name and Location

Site 32, otherwise known as the National Guard Pistol Range, is located at the Savanna Army Depot Activity (SVDA) in Jo Daviess County, Illinois. The United States Environmental Protection Agency's (USE?A) identification number for the SVDA is IL3210020803.

1.2 Statement of Basis and Purpose

This decision document for Site 32 at SVDA presents the selected remedy, as proposed by the U.S. Army (Army) in accordance with the Comprehensive Environmental,Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Supeifund Amendments and Reauthorization Act of 1986 (SARA), which requires the issuance of decision documents for remedial actions taken pursuant to Sections 104,106,120, and 122. : Sections 300.430 (f)(2), 300.430 (f)(4), and 300.435(c)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan (NOP) established the regulatory requirements for this decision document This decision is based on the Administrative Record (AR) for this site and is made by USEPA and the Army in consultation with the Illinois Environmental Protection Agency (lEPA).

13 Description of Selected Remedy

No CERCLA action is necessary for Site 32. Site 32 presents no unacceptable exposure to hazardous substances. The Army removed residual lead bullets, slugs, and shot fi-om the site in December 2013 as a Housekeeping Action (HA). The lead bullets, slugs and shot and associated Site 32 - National Guard Pistol Range Record of Decision m Environmental Quality Management, Inc. June 2014 embankment soils were disposed of off site at a commercial disposal facility. Therefore, no remedial action is necessary to protect human health or the environment EPA and the Army, have determined that no further action is necessary at this site. There is no cost associated with this remedy.

1.4 Statutory Determinations

The No Action remedy selection is based on the investigative results of surface soil, shallow subsurface soil, and groundwater at Site 32. Risk analyses of the current environmental conditions at Site 32. as conducted in the Site Investigation (SI) and Remedial Investigation (RI), concluded that no remedial action is necessary to ensure protection of human health and the environmenL The Army conducted the HA in response to public comments and concerns regarding the continued preseaice of lead bullets, slugs, and shot.

1.5 Authorizing Signatures W The remedy presented in this Record of Decision (ROD) has been selected by USEPA and the in consultation with lEPA.

^ Tuchar^d^c. Karl, Superfiind Division Director, ^7- U.S. Imvironmental Protection Agency, Region 5

_^b4j± onnett. Director f Date lois Environmental Protection Agency

B. Briggs, Acting Cffief erve and Consolidation Branch Base Realignment and Closure Division Site 32 - National Guard Pistol Range Record of Decision Environmental Quality Management, Inc. June 2014

2. DECISION SUMMARY

2.1 Site Name, Location, and Description

The SVDA is located in Jo Daviess and Cairoll Counties, Illinois, and prior to base closure was a facility of 13,062 acres. SVDA is approximately 7 miles north of the City of Savanna and approximately 150 miles west of Chicago. Figure 1 is an aerial view of the SVDA. SVDA is surrounded primarily by agricultural land. It is bound by the Mississippi River to the south and west, the Apple River to the east, and by hills and bluffs to the north.

Figure 1. View of Savanna Army Depot

Site 32, also known as the National Guard Pistol Range, is located in the central portion of SVDA on the west side of West Road (Figure 2). As depicted in Figure 3, Site 32 consists Site 32 - National Guard Pistol Range Record of Decision Environmental Quality Management, Inc. June 2014 of a large natural U-shaped dune with relief of 10 to 20 feet that opens toward West Road. Site 32 covers approximately 0.4 acre and is approximately 180 feet from the Mississippi River. The site is undeveloped. Pistols were fired south toward the dune embankment that was used as a natural backstop for the bullets. The range is bounded to the northwest, southeast, and west by the dune. Beyond the dune to the southwest is a cliff face that drops off to the Mississippi river.

4 Figure 2. Installation Map with Site 32 and various other site locations Site 32 - National Guard Pistol Range Record of Decision EQ Environmental Quality Management, Inc. June 2014

Figure 3. Site 32 View of Embankment o 2.2 Site History and Enforcement Activities SYDA was placed on the National Priorities List (NFL) in 1989. The property has supported a variety of Army missions, ineluding proving and testing of artillery guns, ammunition, and explosives; receiving, storing, issuing, and demilitarizing conventional ammunition and general supplies; manufacturing ammunition-peculiar equipment (APE) and repair parts for worldwide Department of Defense (DOD) support; and providing ammunition and explosive quality assurance for conventional ammunition, guided missiles, large rockets, ammunition components, explosives, and packing material. In 1995, SYDA was selected for elosure under the Base Realignment and Closure (BRAC) process, and all industrial activities ceased when SYDA officially closed in March 2000. Currently, the only on-site Army activities are associated with the assessment and remediation of site-related contamination as required under CERCLA and BRAC, and the preparation for transferring ownership of various parcels of land to non-DOD entities. The range was constructed in 1955 and the date of its last use is unknown. The regularity and frequency of use at the range has not been documented. The range is currently Site 32 - National Guard Pistol Range Record of Decision Environmental Quality Management, Inc. June 2014 inactive and the only activities occuiring at Site 32 have been the environmental investigations conducted by the Army; Dames and Moore conducted the SI in 1994 and Science Applications International Corporation (SAIC) conducted the RI in March 2007. The Amy contracted Environmental Quality Management, Inc. (EQM) to conduct an HA to remove the residual bullets, slugs, and shot. EQM completed the HA in December 2013. Site 32 has not been the subject of any enforcement action.

2.3 Community Participation

Copies of the SI and RI for Site 32 were placed in the information repository (IR) maintained at the Savanna Public Library in Savanna, Illinois and Hanover Public Township Library in Hanover, Illinois. The Proposed Plan for Site 32 was made available to the public and SVDA published a notice of availability of the Proposed Plan in the Savanna Times Journal, Clinton Herald, Dubuque Telegraph Herald, and the Galena Gazette in May 2012. A 30-day public comment period was held from May 14 to June 13, 2012. In addition, a public meeting was held on May 31, 2012, at SVDA Building 247 to present the Proposed Plan to the community. Representatives from the Army, USEPA, and lEPA were available at this meeting to answer questions about the site and the selected remedy. Verbal comments were received during the public meeting and written comments were received by the Army from lEPA, U.S. Fish & Wildlife Service (USFWS), and the SVDA Restoration Advisory Board (RAB) during the public comment period.

2.4 Scope and Role of Operable Unit or Response Action

In 1989, the Army, lEPA, and USEPA signed a federal facility agreement (PEA). The BRAC cleanup team (BCT), which has responsibility for making site decisions across all environmental programs at SVDA, was assembled in accordance with the FFA and consists of representatives from the Army, USEPA, and lEPA. The Army conducted an SI and RI at this site and determined that the past activities do not present a risk to human health and the environment. The Army conducted the HA in response to comments received in response to the No Action Proposed Plan. Site 32 - National Guard Pistol Range Record of Decision Environmental Quality Management, Inc. June 2014

NIM. •

2.5 Site Characteristics

2.5.1 Topography and Surface Features

Site 32 consists of a large, natural, U-shaped dune with relief of 10 to 20 feet that opens toward West Road. The dune surrounds a relatively flat area, approximately 50 by 70 feet. The National Guard Pistol Range firing line was established in this flat area approximately 50 feet north of the dune. Site 32 covers approximately 0.4 acre and measures 125 by 135 feet. Pistols were fired south toward the dune embankment that was used as a natural backstop for the bullets. The range is bounded to the northwest, southeast, and west by the dune. Beyond the dune to the southwest is a cliff face that drops off to the Mississippi River. Groundcover on the leveled portion of the site is primarily grasses, rough-fruited cinquefoil (Potentilla recta), and crown vetch (Coronilla Varia). Small trees are located along the berm surrounding the range, including black oaks (Quercus Velutina), walnuts (Juglans Nigra), black locusts (Gleditsia Triacanthos), and red cedars (Juniperus Virginiana). Several state and federal threatened and endangered plants and animals have been found on or in the immediate vicinity of the SVDA; however, none are present currently at Site 32.

2.5.2 Geology

Based on observations from the installation of a monitoring well, the geology of the site consists of medium-coarse sandy soils. The boring log from this well indicates that the sandy soil continued to the terminal depth of the effort, which was 40 feet below ground surface. Bedrock underlies Site 32 at an estimated depth of 200 feet below ground surface (bgs). Soil conditions ranged from acidic (pH of 5.3) to slightly alkaline (pH of 7.7).

2.5.3 Hydrogeology

Site 32 is approximately 180 feet from the Mississippi River. Because of the site's proximity to the river, the groundwater elevation and the resulting hydraulic gradients in this area of SVDA are affected by the variability of the river stage. Slug testing of the Site 32 - National Guard Pistol Range Record of Decision EQ Environmental Quality Management, Inc. June 2014 groundwater aquifer indicated that the hydraulic conductivity is consistent with a permeable, sandy nature. When measured in 2000 and 2003, water levels within the monitoring well fluctuated between 21 to 31 feet bgs and tended to vary depending on the stages of the nearby river. Water quality measurements indicate that the groundwater is neutral and oxygenated, with low dissolved solids concentrations.

2.5.4 Nature and Extent of Contamination

The SI and RI document the presence of large amounts of copper-jacketed and unjacketed lead bullets on the surface of the range and embankment used as a backstop for fired bullets. In 1992, Dames & Moore collected and analyzed soil and groundwater samples to identify site-related contamination as part of the SI. The SI concluded that the potential for contaminant migration is limited. In 2000, SAIC collected additional soil and groundwater samples as part of an RI to confirm the SI results and to further investigate the potential that activities at Site 32 may have released chemical constituents to the environment. Figure 4 illustrates the locations within Site 32 where soil and groundwater samples were collected in the SI and RI.

2.5.4.1 Surface and Subsurface Soil

In the RI, SAIC collected 13 samples of surface soil and subsurface soil from across Site 32 to determine total metals. Two site-related metals (lead and thallium) were detected in the surface soil [0 to <0.5 foot below land surface (BLS)] and two site-related metals (copper and silver) were detected in the shallow subsurface soil (0.5 to 15 feet BLS). Table 1 summarizes the metal constituents detected in the surface and subsurface soil samples.

Table 1. Metal Constituents Detected in Surface and Subsurface Soil Maximum Frequency of Detected Detection Concentration, (Number Sample Interval (Depth) Constituent mg/kg Detected/Total) Lead Surface Soil (0 to <0.5 foot bis) 346 13/13 Thallium 0.99 5/13 Copper Subsurface Soil (0.5 to 15 feet bis) 7.3 12/12 Silver I.I I/I2 Site 32 - National Guard Pistol Range Record of Decision Environmental Quality Management, Inc. June 2014

2.5.4.2 Groundwater

Two samples of groundwater were collected from the monitoring well at Site 32 and analyzed for volatile organic compounds (VOCs), explosives, metals, anions, and pH. One metal (silver) was detected in the groundwater at 6.3 mg/L; however, silver did not exceed human health screening criteria. Lead was not detected in groundwater at the site. No organic constituents were detected in the groundwater. Five anions (chloride, fluoride, nitrate, phosphate, and sulfate) were detected in the groundwater, but none was detected at concentrations above the human health screening criteria. Table 2 summarizes the metal and non-metal constituents detected in the groundwater samples.

Lsgend CONTOURS (CI = 2 n) E]INSTALLATION BOUNDARY £3 MISSISSIPPI RIVER nSITES I ISITE 32 o + SOIL BORING + D&M SOIL BORING ^ MONITORING WELL

*tAH

SAMPLE LOCATIONS Sill 32 NATIONAL GUARD PISTOL RANGE SAVANN.A ARMY DEPOT ACTI\1TY SAV.WNA, ILLINOIS moiECT DATALWAff^^iJ,^ IWKFA DO 1 " J** ' " EXHlBnt-1 DATE: 3^26/2007

Sees' Figure 4. Site 32 RI - Soil Sampling Points Site 32 - National Guard Pistol Range Record of Decision E]Q Environmental Quality Management, Inc. June 2014

Table 2. SVDA Site 32 - Metal and Non-Metal Constituents Detected in Groundwater Maximum Detected Frequency of Detection Constituent Concentration, ng/L (Number Detected/Total) Silver 6.3 1/2 Chloride 1280 2/2 Fluoride 110 2/2 Nitrate 1460 2/2 Phosphate 245 1/2

2.6 Current and Potential Future Site and Resource Uses

Site 32 remains an un-developed parcel. Public access to the site is prohibited; a secure chain- link fence restricts access to this parcel as well as much of the upper facility. No activities other than the SI and RI have taken place at Site 32 since SVDA closed. The Army intends to transfer Site 32 to the USFWS for incorporation into a wildlife refuge.

2.7 Site Risks

Risks at Site 32 were evaluated as part of the SI and RI. In the SI, Dames & Moore concluded that the potential for contaminant migration at Site 32 is limited because no compounds were detected above background. They indicated, however, that further investigation was needed to assess the lead in the soils of the embankment based on visual observation of lead bullets. The analytical results of the RI were compared against a number of screening criteria, including human health and ecological values as well as background concentrations, to determine if a chemical qualifies as a chemical of potential concern (COPC). Lead in the surface soil at Site 32 was identified as an ecological COPC. Table 3 summarizes the risk assessment conducted as part of the RI.

10 Site 32 - National Guard Pistol Range Record of Decision EQ Environmental Quality Management, Inc. June 2014

2.7.1 Human Health Risks

The evaluation of the human health risk was based on the results of the risk-based screening. A formal human health risk assessment was not conducted as part of the RI. The results of the risk screening show that the detected site concentrations do not exceed regulatory screening values. Furthermore, the results of the additivity screening show that the combined cancer and non-eancer risks for the detected constituents are below the target ranges for human health and the state's Tiered Approach to Corrective Action (TACO) objectives. None of the chemicals detected were identified as a COPC to human health.

Table 3. SVDA Site 32 - Risk Assessment Frequency Protection of Human Migration to Maximum of Health Groundwater Detected detection Region 9 Region 9 Sample Concen­ (Number PRC TACO PRO TACO Ecological Screening Interval tration, Detected/ Screening Screening Screening Screening Screening Criteria (Depth) Constituent mg/kg Total) Value Value Value Value Criteria Exceeded Surface Soil (0 Lead 346 13/13 400 400 N/A N/A 85 (>esv) to <0.5 foot Thallium 0.99 5/13 5.16 6.30 N/A 3.00 1.00 None BLS) Subsurface Soil Copper 7.3 12/12 3,129 2900 N/A 11,000 36 None (0.5 to 15 feet Silver 1.1 1/12 391 390 2.00 1.5 4.00 None BLS) Notes: TACO migration to groundwater screening values for the pH range of 6.65 to 6.89 were selected for inorganics in the surface soil and shallow subsurface soil based on a median pH value of 6.7 determined using site-specific pH values of 0.34,6.07, 7.3, and 7.72.

N/A - No screening value available for comparison. >esv - Detected constituent concentration is greater than the ecological threshold value.

Source - RI, SAIC 2007

2.7.2 Ecological Risk Assessment

An ecological screening consisting of a qualitative habitat screening; a persistent, bioaccumulative, and toxic (PBT) screening, and an ecological toxicity screen were performed as part of the RI. Screening results indicated that lead was identified as an ecological COPC in the surface soil only, not the shallow subsurface soil. The weight of evidence presented in the RI indicated that although the lead concentration exceeded the ecological screening value, the screening value in this case overestimated the lead risk because the effective area of contamination is limited to Site 32 (0.4 acre) and exposure of

11 Site 32 - National Guard Pistol Range Record of Decision m Environmental Quality Management, Ino June 2014 wildlife and terrestrial plants to elevated concentrations of lead is limited spatially. The potential ecological risk is further minimized by the small size of Site 32, and the most impacted area (the earthen backstop/berm) is a smaller portion of the site's total area. This area is too small to support foraging by wildlife exclusively within its boundaries, as assumed in the ecological screening. Lead was identified as an ecological chemical of concern based on the maximum concentration of lead detected in the RI. The lead concentration exceeded the ecological screening value in only 1 sample out of 13 total samples. The average lead concentration of all 13 samples collected from locations throughout Site 32 was below the ecological screening value. This must be considered as a mitigating factor in evaluating the risk calculated by the ecological screening.

2.7.3 Conclusion

USEPA and the Army have concluded that exposure to hazardous substances at Site 32 presents an acceptable risk. USEPA and the Army have further concluded that no remedial action is necessary to protect human health and the environment. The Army conducted the HA to remove the source of lead and thereby further reduce and/or eliminate future risks to human health and the environment. Therefore, the No Further Action approach is appropriate.

2.8 Documentation of Significant Changes

A Proposed Plan for Site 32 was released and advertised for public comment in May 2012. The Proposed Plan identified No Action as the selected remedy. The Army reviewed verbal and written comments made during the public meeting and received during the public comment period and determined that an HA to remove the residual bullets, slugs, and shot was appropriate. The Army completed the HA in December 2013. No other significant changes to the proposed remedy were necessary or appropriate.

I

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3. RESPONSIVENESS SUMMARY

3.1 Overview

In accordance with CERCLA § 117(a), the Army held a public meeting and published Site 32 No Action Proposed Plan for a 30-day public comment period. The Army, in conjunction with the lEPA, USEPA, and USFWS, are considered stakeholders for Site 32. As detailed in the Proposed Plan, the Army has determined that the No Action remedial approach is appropriate for the closure of this site. lEPA and USEPA concur with this remedy. This responsiveness summary documents the Army's responses to the oral and written comments received during the public meeting and the 30-day comment period. Attachment A contains the transcript of the public meeting and Attachments B, C, and D contain the written comments from lEPA, USFWS, and RAB, respectfully.

3.2 Background on Community Involvement

The No Action Proposed Plan was added to the information repositories for public review at the libraries in Savanna and Hanover, Illinois on May 14, 2012. An additional copy was made available by appointment at the Army's on-site office at SVDA. Starting on May 14, 2012, a notice of the Proposed Plan and public meeting was advertised for a 2-week period in the newspapers serving the communities of Savanna and Galena, Illinois, and Clinton and Dubuque, Iowa. The Army held a public meeting at the former SVDA on May 31, 2012 to present the No Action Proposed Plan and receive comments. Attendees of the public meeting included one representative of the USEPA, three representatives of the lEPA, two representatives of the USFWS, and one representative of the RAB in addition to representatives of the Army, U.S. Army Corps of Engineers (USACE), and their subcontractors.

13 Site 32 - National Guard Pistol Range Record of Decision EQ Environmental Quality Management, Inc. June 2014

3.3 Site Characteristics

In 1995, SVDA was selected for closure under the BRAG process, and all industrial activities ceased when SVDA officially closed in March 2000. Currently, the only on-site Army activities are the assessment and remediation of site-related contamination required under CERCLA and BRAC, and the preparation for transferring ownership of various parcels of land to non-DoD entities. Site 32 is located on a parcel of land that will be transferred to the USFWS. In 1994, SVDA completed an SI at Site 32 and an RI was completed in 2007. The SI and RI both document the presence of large amounts of copper-jacketed and unjacketed lead bullets on the surface of the range and embankment used as a backstop for fired bullets. The SI concluded that the contaminant migration potential is limited, and the RI recommended No Action based on the characterization of site contamination and the assessment of human health and ecological risk. Therefore, only the No Aetion alternative is warranted. The SI and RI were reviewed and accepted by the lEPA and USEPA; copies are available in the administrative record/information repositories.

3.4 Key Issue

The key issue common to all oral and written comments received pertains to the No Action approach regarding the residual bullets and casings present at the site. 1.) USFWS indieated that the presence of the bullets and easings constitutes an ecological risk that would prevent it from incorporating this parcel into the existing wildlife refuge as is expected in the memorandum of agreement (MOA) between the USFWS and the Army for land parcels at SVDA. 2.) lEPA indicated that the bullets present a future risk to the environment through degradation and biomagnification. lEPA recommends removal of the bullets and subsequent recycling/disposal of the metal debris as a "best management praetice." lEPA will not support a No Action ROD. 3.) USEPA commented in the publie meeting that the No Action approach is appropriate relative to CERCLA because the results of the previous investigations failed to identify any risk to human health and the environment. The RI recommended the No Aetion remedial approach for Site 32, and the results of the RI were reviewed and accepted at that time by both USEPA and lEPA. 4.) RAB commented that the small size of the area impacted by the bullets and the ability to screen the bullets from the surface soil and shallow subsurface soil allow the Army to W' remove the point source of contamination relatively easily and cost-effectively.

lT~ Site 32 - National Guard Pistol Range Record of Decision Environmental Quality Management, Inc. June 2014

3.5 Summary of Comments Received and Army Responses

1) Comment: The lead bullets present an unacceptable ecological risk to wildlife receptors. Response: Lead was detected in the surface soil at Site 32, and the lead concentrations were compared against three screening criteria to evaluate the risk to human health and the environment as part of the RI. Lead was not identified as a risk to human health, but was identified as an ecological chemical of concern based on the maximum concentration of lead detected in the remedial investigation. The lead concentration exceeded the ecological screening value in only 1 sample out of 13 total samples collected from locations throughout Site 32. The average lead concentration of all 13 samples was below the ecological screening value. This must be considered as a mitigating factor in evaluating the risk calculated by the ecological screening. The potential ecological risk is further minimized by the small size of Site 32. The site is approximately 0.4 acre, and the most impacted area (the earthen backstop/berm) is a smaller portion of that total area. This area is too small to support foraging by wildlife exclusively within its boundaries, as assumed in the ecological screening.

2) Comment: The No Action Proposed Plan and alternative doesn't account for future V,. degradation and biomagnification of lead. Response: As part of the RI, future risks to human health and the environment were evaluated and the leachability of the metal constituents, including lead, was analyzed and evaluated. The RI did not identify any undue risk based on the degradation. Although natural degradation is acknowledged to be occurring, its rate is undetermined, and the degradation that has occurred over the past 40 years has failed to increase the mobility of the lead for detection in the subsurface soil and the groundwater, as sampled during the SI and RI.

3) Comment: The potential ecological risk posed by the lead bullets violates the MOA with USFWS. Response: The Army has complied with CERCLA and does not concur that the proposed No Action approach violates the MOA with USFWS.

4) Comment: lEPA wants U.S. Army to follow Best Management Practices and remove the spent bullets. Response: Comment noted. See attached letter dated 6 July 2012 (Attachment E).

5) Comment: Support of the No Action Proposed Plan. Response: The USEPA concurs with the No Action Proposed Plan.

15 Site 32 - National Guard Pistol Range Record of Decision Environmental Quality Management, Inc. June 2014

6) Comment: Screening of the soil and removal of the bullets is easy and relatively cheap. Response: The removal of the bullets will require excavating the surface soil and shallow subsurface soil and processing the excavated material through a screen to separate the soil from vegetative and metal debris that exceeds the screening mesh. Off-site disposal of the oversize debris will be required, and screened soil can be returned to the site. Screening will effectively remove only those bullets that exceed the mesh intervals of the screen. Lead fragments will most likely pass through the screen and remain entrained in the soil. The removal of the bullets is a qualitative process, and any subsequent reduction in the soil lead concentration cannot be compared to a quantitative standard or remedial objective to determine its effectiveness. The cost associated with this screening effort is relative. The screening cost will be lower than a removal action in which the surface and shallow surface soils are excavated and disposed of off site, but it also exceeds the cost of the preferred No Action alternative. Cost implications must be evaluated by the source funding the proposed action and a determination made in accordance with budgetary constraints of that source.

3.6 Housekeeping Action

In response to the comments and concerns detailed above, the Army contracted EQM to complete an HA to remove the lead bullets, slugs, and shot from the surface soil and shallow subsurface soil of the embankment at this site. EQM conducted the HA in December 2013. EQM excavated the surface and shallow subsurface soils contaminated with bullets and disposed of the material off site. EQM did not mechanically screen the bullets out of the soil. The removal of the lead source material significantly reduces, if not eliminates altogether, future site risks at Site 32. EQM's Completion Report is contained in Appendix F.

16 Site 32 - National Guard Pistol Range Record of Decision Environmental Quality Management, Inc. June 2014

4. REFERENCES

Dames & Moore. Remedial Investigation Report, Savanna Army Depot Activity, Savanna, Illinois, Preliminary Draft. Prepared for the U.S. Army Environmental Center. June 1994. SAIC. RI Report for Sites 11, 32, and 82SS. Final. Savanna Army Depot Activity, Savanna, Illinois. Prepared for the U.S. Army Corps of Engineers, March 2007.

17 Site 32 - National Guard Pistol Range Record of Decision Environmental Quality Management, Inc. June 2014

ATTACHMENT A

PUBLIC MEETING TRANSCRIPT, MAY 31,2012 1 PUBLIC HEARING w 2 Held 3 Thursday, May 31, 2012 at 6:00 p.m. 4 Building 247, SVDA 18935 B Street 5 Savanna, Illinois 61074 6 7 Attendees: 8 JOHN E. CLARKE, Installation Manager/BRAC Environmental Coordinator 9 CRAIG HOBY, Senior Project Manager 10 LYNN EICH Environmental Quality Management, Inc. 11 TOM BAROUNIS 12 U.S. EPA 13 CLARENCE SMITH CHARLENE FALCO 14 MICHELLE TEBRUGGE Illinois EPA 15 ALAN ANDERSON 16 ED BRITTON U.S. Fish and Wildlife Service 17 TODD KNUTH 18 U.S. Army Corps of Engineers 19 JO CAREY Savanna Army Depot 20 TERRENCE INGRAM 21 Restoration Advisory Board 22 23 24 Reporter: Bev Herring-Black, GSR, RPR, CRR 25

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 2 1 INDEX

2

3 OPENING REMARKS: Mr. Clarke 3 4

5 SLIDE PRESENTATION: Mr. Hoby 5 6 7 COMMENTS (First Time to Speak): Mr. Ingram (a question) 11 8 Mr. Britton 14 Mr. Smith 16 9 Mr. Ingram (comments) 20 Mr. Barounis 24 10 Ms. Falco 29 Mr. Anderson 30 11 12

13

14 CLOSE of RECORD Mr. Clarke 38 15 16 17 18 19 20

21 22 23 Certificate of Court Reporter 39

24

25

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 3 1 PROCEEDINGS

2 MR. CLARKE: Good evening, Ladies

3 and Gentlemen. My name is John Clarke. I'm the

4 Installation Manager and Base Realignment and

5 Closure Environmental Coordinator here at the

6 Savanna Army Depot.

7 This meeting is being conducted to

8 discuss the preferred remedial action presented

9 in the No Action Proposed Plan for Site 32 - the

10 National Guard Pistol Range.

11 The U.S. Army, in conjunction with

12 the U.S. EPA, represented by Mr. Tom Barounis, and

13 the Illinois EPA, represented by Ms. Charlene Falco,

14 is requesting public comment on this Proposed Plan.

15 Said plan was prepared in accordance with Section

16 117(a) of the Comprehensive Environmental Response

17 Compensation and Liability Act, known as CERCLA, of

IB 1980 and Section 300.430(f)(2) of the National Oil

19 and Hazardous Substance Pollution Contingency Plan,

20 which provide the opportunity for public input in

21 the site decision-making process.

22 The Proposed Plan summarizes the

23 no action alternative evaluated in the Remedial

24 Investigation/Feasibility Study performed on Site

25 32 and identifies it as the preferred remedy.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 4 1 The RI/FS report referenced in the

2 Proposed Plan is available for public review in the

3 Hanover and Savanna Public Libraries,

4 As part of the process required by

5 CERCLA, the Army established a 30-day comment period

6 that began on the 14th of May and ends on the 13th

7 of June, 2012, Written comments postmarked before

8 midnight on that date will be considered,

9 After evaluating all of the written

10 comments submitted by the public, the Army will

11 finalize the proposed alternative into a Record

12 of Decision or select another remedy based upon

13 new information or on the comments received from

<7 14 the public, I

15 Before I turn the time over to Craig

16 Hoby, Charlene, why don't you introduce Michelle

17 and Clarence as members of the Illinois EPA,

18 MS, FALCO: I'm the Project Manager

19 for Illinois EPA, and with me tonight is Michelle

20 Tebrugge to my immediate left. She's the Community

21 Relations Coordinator from Illinois EPA,

22 And sitting next to Michelle is

23 Mr, Clarence Smith, He is the Federal Site

24 Remediation Section Manager, He is two levels

25 above me as our supervision.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 5 1 MR. CLARKE: Thank you.

2 I'll turn the time now over to

3 Mr. Craig Hoby, of the firm of Environmental Quality

4 Management, to present the Proposed Plan and to field

5 any questions that the audience may have.

6 Please state your name before asking

7 questions in order that the court recorder can keep

8 an accurate record of who asks questions.

9 Mr. Hoby, the time is yours.

10 MR. HOBY: Thank you, John.

11 Again, my name is Craig Hoby. I'm the

12 Project Manager for Environmental Quality Management.

13 We go by the acronym of EQ or EQM. We are under

14 contract with the Army Corps of Engineers to secure

15 closure on Site 32 among five other contracts that

16 we have or five other sites, but tonight this

17 presentation is specific to Site 32.

18 I trust everybody has a copy of the

19 Proposed Plan. There are courtesy copies here if 20 you don't have one.

21 Again, I have a few slides I'd like

22 to present and discuss; and then, afterwards, we

23 can take questions and any comments at that point.

24 (Pause to begin slide projector 25 operation.)

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 6 1 It just needs to warm up a little bit.

2 MS. CAREY: Can you guys see that

3 all right back there?

4 (Affirmative responses received.)

5 MR. HOBY: Okay.

6 The stakeholders involved with Site 32

7 are those people most represented here in this room

8 today. U.S. Army is represented by Mr. John Clarke.

9 They are the current landowner.

10 U.S. Army Corps of Engineers is

11 assisting the U.S. Army in closure of the Savanna

12 Army Depot facility. They're represented by Mr. Todd

13 Knuth.

14 Again, Environmental Quality Management,

15 Lynn Eich and myself, we're the contractors under

16 contract with the Army Corps for Site 32.

17 Then we have Illinois Environmental

18 Protection Agency, represented by Charlene Falco and

19 others. Charlene has been the main point of contact.

20 Then we have U.S. Environmental

21 Protection Agency, U.S. EPA, represented by Mr. Tom

22 Barounis. 23 Then U.S. Fish and Wildlife Service,

24 they are scheduled to receive this site, to receive

25 Parcel 9B, which does include Site 32, so they are

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 7 1 the future landowners.

2 Here's a photo of the site that I took

3 back when we initially were preparing a proposal for

4 this contract. It shows the site, which, that would

5 have been almost two years ago. 1 don't think much

6 has changed with the site. There has been absolutely

7 no development there.

8 This shows the U-shaped relief area;

9 and the area that the Site 32 berm where the bullets

10 were actually trapped is present, if you can see the

11 cursor moving on the screen there. Oops. There we

12 go.

13 MR. EICH: Goes all the way from there.

14 Right there.

15 MR. HOBY: Yeah. Thanks, Lynn.

16 So that's the area that is the actual

17 bullet trap that was sampled, and that was the

18 focus of the remedial investigation and the site

19 investigations that were completed.

20 So you can see, it's a relatively small

21 area; and the Mississippi River is further to the

22 west, behind the hill there. Okay.

23 Results of previous investigations:

24 The Army has contracted and conducted a site

25 investigation which was a preliminary investigation,

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 8 1 and that occurred back in 1994, and that recoininended

2 that a remedial investigation be conducted, which a

3 firm by the name of SAIC conducted that and issued

4 a report in 2007.

5 The basis of the Proposed Plan draws

6 from primarily the remedial investigation and the

7 results of the site investigation.

8 The main emphasis of those

9 investigations were to determine what impact there

10 has been on the site by the operation of the pistol

11 range, so, is the soil contaminated, is the ground-

12 water contaminated? Those were the main questions.

13 And, if so, the next question is, does

14 the contamination present a risk to human health; and,

15 likewise, does it present a risk to the environment,

16 the flora and the fauna, the wildlife and the

17 vegetation? And then, additionally, what should

18 be done to address that contamination based on the

19 levels and the impacts?

20 This is a slide that I took out of

21 the Remedial Investigation that was done, again, by

22 SAIC. It shows the sampling points that follow in

23 the U-shaped pattern of the relief. It illustrates

24 the firing positions there closest to the road and

25 then the bullet trap sampling that occurred.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 9 1 Again, this is a slide that is — the

W 2 source of this slide is the Remedial Investigation.

3 This is a summary slide, basically a data table

4 summarizing the analytical that went along with

5 the sampling. And of note here, in the Remedial

6 Investigation, they discovered or detected four

7 constituents that are related to the firing of

8 bullets, lead bullets, the copper jackets and

9 munitions used at a pistol range. Those four

10 constituents are lead, thallium, copper and silver.

11 The lead and the thallium were only

12 detected in the surface soil, that is, in the interval

13 of 0 to 6 inches. Copper and silver were detected at

14 a deeper depth.

15 The next column over again indicates the

16 maximum concentration of each of those constituents.

17 This is not the average. This is the sole maximum.

18 All the units, the concentrations

19 are expressed in units of milligram per kilogram,

20 otherwise known as part per million.

21 The next column over, you'll see

22 Freguency of detection, meaning that, of the 13

23 samples for lead, for example, lead was detected in

24 all 13 samples that were collected, whereas thallium

25 was only detected in 5 of the 13. So it goes to

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 10 1 show more distribution of the constituents across

2 the area, the sampling area.

3 So that indicates what contamination

4 was present, impact in the surface, in the shallow

5 subsurface soils.

6 Then the remaining columns to the right

7 are an assessment of those concentrations as posed to

8 the screening criterias to determine if there's any

9 risk to human health in the environment.

10 Of interest there is the TACO value.

11 The screening value for lead you'll see is listed

12 as 400 part per million, whereas the maximum detected

13 concentration of lead in the surface soil was 346, 14 so the maximum concentration did not exceed the

15 screening value for the TACO level.

16 The next column over is the Migration

17 to Groundwater. Groundwater was analyzed during

18 the site investigation. There was a monitoring

19 well that was established; and both in the remedial

20 investigation and in the site investigation,

21 groundwater samples were collected; and none of these

22 four constituents — excuse me — silver was detected

23 in groundwater but well below the threshold value,

24 and so the additional analytical was done to look at

25 the leachability of these metals to try to assess the

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 11 1 migration to groundwater pathway, and none of the

2 values exceeded the criterias. 3 The next column over is the Ecological

4 Screening Criteria. And of note there is, the

5 screening value for lead is 85, whereas the maximum

6 concentration detected was 346, and the next column

7 over shows that that is an exceedence of that value.

8 So, again, these — all this data is

9 based on soil concentrations.

10 The next slide shows the concentrations

11 of constituents that were detected in the groundwater

12 at the site. There was one metal and a group of

13 anions that were detected, again, well below all

14 the screening values; and based on the low level of

15 concentration of these, it was determined that the

16 groundwater is not impacted by the residual impact

17 in the surface soil.

18 MR. INGRAM: Lead wasn't checked?

19 MR. HOBY: Excuse me?

20 MR. INGRAM: Wasn't lead checked? Does 21 it mention it?

22 MR. HOBY: Yes, lead was checked, but

23 it wasn't detected.

24 MR. INGRAM: It wasn't detected at all?

25 MR. HOBY: Not in the groundwater.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 12 1 MR. INGRAM: Okay.

2 MR. HOBY: Yeah, these values are for

3 only those constituents that were detected.

4 So, based on the recommendation in

5 the Remedial Investigation, this Proposed Plan

6 is authored and incorporates that the previous

7 investigations found no impact to groundwater, that

8 the concentrations in the soil presently present no

9 risk to human health now, nor in the future.

10 Again, the slight ecological risk that

11 was detected based on lead being at the concentration

12 — the maximum concentration as reported was 346 part

13 per million. That slight ecological risk, when it's

14 compared against the regulatory guidance and screening

15 levels, seems to be overestimated.

16 There's — when you take into account

17 several factors at the site -- one, that the site is

18 extremely small size — the site is approximately

19 four-tenths of an acre, and most of the ecological

20 screening values, they're based on area size of an

21 acre; so we have an area that's much smaller than

22 that that's impacted.

23 The extent of the contamination,

24 it's limited. Lead exceeded the ecologic screening

25 value in only 3 of the 13 samples. Again, lead was

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 13 1 present — detectable concentrations of lead was

2 detected in all 13 samples, but only 3 of those 13

3 presented concentrations above that 85 part per

4 million level.

5 So, we only have 3 of 13 there. And

6 then the ecological screen is used — the exceedence

7 that was reported based on the ecological screen

8 used the maximum lead concentration of 346 part per

9 million when, if you were to take the average lead

10 concentration of all the samples, all 13 samples,

11 that — the erethitic mean is 75 part per million,

12 which, again, the screening level is 85 part per

13 million. So the actual mean of all 13 samples is

14 10 part per million under that screening value.

15 So, based on these three considerations,

16 the recommendation was to go for no action because

17 the ecological assessment may be overly conservative.

18 So, then, the No Action approach is

19 selected. It is appropriate. Site 32 does not pose

20 a risk to human health and the environment.

21 The purpose of the No Action and

22 the Proposed Plan is to fulfill the regulatory

23 obligations that the Army has under CERCLA, and it

24 would facilitate the transfer of this property to the

25 U.S. Fish and Wildlife Service for their purposes.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 14 1 And that's my final screen.

2 With that, I'd open it up to questions 3 and comments.

4 Again, for Bev's purpose, if you would,

5 just state your name before you state a question or a

6 comment so that she can accurately record who you are

7 and your comment, please.

8 MR. BRITTON: A comment.

9 Ed Britton, with the Fish and Wildlife

10 Service. We submitted formal comments, but I'd like

11 to make some additional comments on this.

12 You know, on page 6 of this, your

13 Evaluation of Preferred Alternatives, you know, it

14 talks about utilizing permanent solutions, and No

15 Further Action confuses me how this is a permanent

16 solution.

17 You've got thousands of lead bullets

18 laying out there, you've already identified elevated

19 concentrations of lead. Even though it's limited

20 spatially, you've still got thousands of bullets out

21 there, lead bullets, laying there. They're going to

22 be there for decades. I don't understand how you can

23 say this is a permanent solution that's protective of

24 the human health or the environment. 25 That's just a comment. I'm not asking

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 15 1 for you to answer it, but — 2 It says, "...poses no unacceptable risk

3 to human health or the environment."

4 I don't understand how you can make

5 that statement about this statement after you've said

6 "lead"...is "an ecological chemical of potential

7 concern with surface..."

8 Elevated concentrations of that is

9 limited spatially, even though all the justifications,

10 it's not high enough to justify a different remedy.

11 You've still got four-tenths of an acre with thousands

12 of lead bullets out there in the soil that's going to

13 be breaking down for years.

14 We've made other comments. This has

15 been a longstanding issue with this agency. Our

16 memorandum agreement says that "the remedy should

17 be protective of the environment."

18 When it specifically talks about

19 selection of response actions, it says that "the

20 remedy should be consistent with the interior

21 statutory responsibilities for the management of

22 National Wildlife Refuge."

23 Those lead bullets are out there.

24 We cannot manage that area as a National Wildlife

25 Refuge. So I just wanted to make those comments.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 16 1 MR. HOBY: Thank you, Ed.

•'••I 2 MR. SMITH: The State of Illinois has

3 also been very concerned about the site. And we're

4 concerned about all shooting ranges, whether they be

5 public, private, for the military use, or v\/hatever;

6 and over the past decade or so, we've developed a

7 process by which to address these types of small

8 arms ranges within Illinois.

9 1 echo Ed's comments that, while

10 your chemical analysis of the soil shows limited

11 degradation of the lead out there, 1 have at my desk

12 a cup full of projectiles: they're lead, 158-grain

13 wadcutter bullets; they're copper-jacketed lead

14 .38-caliber ball bullets; they're copper-jacketed

15 lead .45-caliber ball bullets. All those projectiles

16 are out there. You can walk out right now, reach

17 down and pick them up. 18 Our concern is biomagnification through

19 the fragments of lead that are there, that will be

20 eaten by prey animals that will end up in the apex

21 predator, the bald eagle, that's here. That's a

22 serious issue. 23 Our approach to dealing with this

24 is based on a court case that came out of the

25 Federal 2nd District Court of Appeals. It's called

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 17 1 Connecticut Coastal Fishermen's Association versus

•Iht.l 2 Remington Arms Company, and that case talked about

3 all of this and how we came to deal with the lead

4 contamination at shooting ranges.

5 EPA wrote a Best Management Practices

6 guidebook for it. It's EPA Publication 902-B-01-001.

7 The most recent version is published in June of 2005.

8 What the case decided was that lead,

9 when left out in the open, the facts in the guidebook

10 says it oxidizes when exposed to air and it dissolves

11 when exposed to acidic water. Rainfall in this area

12 is typically slightly acidic, around 4.5 to 5.0 pH.

13 We're going from there.

14 The lead bullets that I have in my

15 office have a coating of lead oxide on them, so the

16 material is becoming mobile in the environment.

17 The environment that it's in is a

18 sand. I'm not surprised you didn't find it in the

19 groundwater, because it's going to move very guickly.

20 You might find remnants of it, but you're not going

21 to find it in high concentrations, because the sand

22 that the berm is in moves very quickly. Once it

23 hits the aquifer level of the Mississippi River,

24 it's probably gone and you're not going to find it.

25 So that's another very important component of all

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 18 1 this.

2 The court found in the Connecticut

3 Coastal Fishermen's case "that lead shot in

4 projectiles meet the statutory definition of solid

5 waste because these materials were 'discarded (i.e.

6 abandoned)' and 'left to accumulate long after they

7 have served their intended purpose.' Further, the

8 court concluded that based upon toxicity testing

9 and evidence of lead contamination, lead shot was

10 a hazardous waste subject to RCRA."

11 This is in the Connecticut Coastal

12 Fishermen's case.

13 They go on to talk a little bit more

14 about, "The important point to consider — "

15 This is in EPA's guidance document.

16 "The important point to consider here is that if

17 lead shot and clay target debris are discarded (i.e.

18 abandoned), these materials are considered a solid

19 waste as defined in the statute" — and the statute

20 is the Resource Conservation and Recovery Act of

21 1976 as amended — "and the facility may be subject

22 to governmental or citizen suits."

23 And here's the key: "If, on the other

24 hand, the discharged" projectiles, "lead" projectiles,

25 are "recovered or reclaimed on a regular basis, no

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 19 1 statutory solid waste (or hazardous waste) would

2 be present and imminent hazardous suits would be

3 avoided." 4 That's how we've tried to address

5 shooting ranges in Illinois, work with the responsible

6 parties to say, Okay, go out, screen the berm, remove

7 the lead projectiles down to a certain size, sell

8 those lead projectiles as scrap metal, recover the

9 scrap metal value, restore the area to a natural state

10 and we get on with life. We avoid RCRA implications,

11 we avoid the ecological risks through biomagnification

12 of elemental lead in the apex predators and everybody

13 is happy.

14 We've been consistent with this position

15 with the Army since July 7 of 2008. We've echoed this

16 position over and over again. I have three letters:

17 July 7 of 2008/ February 15 of 2011; and the most

18 recent one. May 29th of this year. That's what we

19 do. We try to treat everybody that has a shooting

20 range that changes the land use.

21 That land use is not going to be a

22 shooting range. It hasn't been a shooting range for

23 probably 50 or 60 years, and for the Army to sit here

24 and say that it poses no threat and no action is the

25 appropriate remedy, the state cannot accept that.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 20 1 The state will not accept that.

2 If the remedy chosen is not changed,

3 the state will not concur with the Record of

4 Decision. That's one of the nine criteria of CERCLA

5 that needs to be met, state acceptance.

6 MR. HOBY: Yes, sir.

7 MR. INGRAM: Terrence Ingram, Apple

8 River, Illinois; member of the RAB board and

9 representing the RAB board, as nobody else is here.

10 And Simon Bernstein told me I have his non- —

11 irrevocable, his power of attorney to speak for him

12 and the RAB board.

13 We've discussed this in the past.

14 You say it's a small area. I agree. And the

15 concentration where the lead is most is even smaller.

16 MR. HOBY: (Indicates affirmatively.)

17 MR. INGRAM: So the cost of cleaning

IB that up is so little, go ahead and do it. And I

19 can't see -- we're worried here on the RAB board

20 with lead paint dropping off the buildings and

21 contaminating the ground around it.

22 It seems to me that lead shot in the

23 ground is a heck of a lot more than lead paint and

24 gives us a lot more lead that's going to be there,

25 as Ed says, for years, and it's going to — it's a

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 21 1 problem. 2 It could be cleaned up very simply.

3 You go under, you scoop about a foot off the ground,

4 take the foot off and screen it as you go and put the

5 sand back in place. 6 It's one of the simplest, cleanest

7 things to clean up here that we've got of any of the

8 sites, and now you want to walk away without cleaning

9 it up. It's one that could be cleaned up very easily

10 and should be cleaned up.

11 The RAB board, the public members of

12 it have talked about this and our agreement that it

13 should be cleaned up before it's transferred. We've

14 gone on record in the past, every site before it's

15 transferred should be cleaned up. And that should

16 be, not just left.

17 I can't — I don't know — I don't —

18 when you talk about the screen values here, they're

19 developed by somebody, but — it says several state

20 and federal threatened, endangered plants and animals

21 have been found on or in the immediate vicinity of

22 the SVDA. None are presently at the site.

23 Who's done that study? Who has looked

24 at that site to see what's there? Just to say it's

25 not there doesn't pass in my book. I want to see

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 22 1 that study that shows me what plants and what animals

•Mil 2 are there and which ones would be affected.

3 We haven't had that study done. We're

4 just trying to walk away from it without getting all

5 the information that we need before we do anything.

6 But the simplest thing is to just go

7 in, get a scoop and scoop up the top foot and sift

8 it through the sand, sift out the copper and sift

9 out the lead, the shot, turn the sand back and you're

10 done.

11 It's one of the simplest, one of the

12 cheapest cleanups we could have here at the Army, and

13 it would eliminate a real problem. And I'd think the

14 Fish and Wildlife then would be willing to accept it.

15 And I'd think that the EPA would be willing to accept

16 it. 17 But to walk away and say the best

18 alternative is to do nothing, no, that's not the best

19 alternative. The best alternative is to clean up the

20 site, and that's what the RAB board has insisted all

21 along. 22 It would be simple. The whole thing is

23 only four-tenths of an acre. My gosh, where the lead

24 is the greatest is probably one-tenth of an acre, and

25 it would not take much to get that off there. Clean

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 23 1 it up and get all the shot out of there. Okay.

2 MR. SMITH: And the Best Management

3 Practices that the EPA has developed we've embraced,

4 the state of Florida has embraced, New Jersey has

5 embraced them. New York has embraced them.

6 The Best Management Practices are out

7 there, because, when you get Into the regulation of

8 firing ranges and the Intended purposes of ammunition

9 as you discharge It, you face some very difficult

10 legal definitions within the RCRA statute.

11 Implementing the Best Management

12 Practices Is really, as this gentleman said, a pretty

13 meager action. It doesn't take a lot of effort to

14 do. There's companies out there that do It. This

15 document, EPA's document, has a list of people In It

16 that do this sort of work.

17 The other Best Management Practices,

18 after you screen the lead, put down an amendment.

19 Put some phosphate fertilizer or a sulfIde-contalnlng

20 material to tie up any of the remaining lead that's

21 dissolved, the 346 parts per million, and tie It up

22 so that that's not bloavallable as well through the

23 plants and we're done. It's very meager. It's a

24 very simple solution to a complicated problem.

25 There are several — several ranges on

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 24 1 this post. We're not asking to go out and excavate

2 and remove every bit of lead. We're asking to

3 implement the Best Management Practices. That's

4 what we ask private citizens to do in the state

5 when they close a shooting range and the land use

6 changes, implement the Best Management Practices.

7 Move forward with that. That satisfies the state.

8 Many people try to get a No Further

9 Remediation letter through our voluntary cleanup

10 program. If they implement the Best Management

11 Practices, that's usually what they get; or they

12 get a No Further Action letter under Section 4(y)

13 of the Illinois Environmental Protection Act.

14 That's how we deal with these problems. To do

15 nothing is the wrong answer.

16 MR. CLARKE: John Clarke from the

17 U.S. Army. 18 Tom Barounis from the U.S. EPA, can

19 you give us U.S. EPA's position on this issue?

20 MR. BAROUNIS: Sure.

21 This is Tom Barounis with the U.S. EPA.

22 U.S. EPA considers the No Action

23 alternative appropriate for this site for the

24 following reasons: 25 Superfund sites are evaluated in terms

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 25 1 of risk to human health and the environment. The way

2 that we evaluate these risks is based upon our Risk

3 Assessment Guidance Procedures for both human health

4 and the environment.

5 Based on the data that were collected

6 during the Remedial Investigation and the

7 concentrations of metals contaminants at issue in

8 the soils and taking those data and plugging them

9 into the appropriate risk calculations, the

10 determination was made that, as the site stands now

11 and for the foreseeable future, there does not appear

12 to be a risk to human health or the environment.

13 U.S. EPA and Illinois EPA accepted the

14 results of the Remedial Investigation. In accepting

15 results that indicate that there is no risk to human

16 health and the environment, we are not — in term —

17 for the purposes of CERCLA, for the purposes of the

18 Superfund cleanup, those results imply that no action

19 is a totally acceptable remedy or not required -- the

20 lack of a requirement for a remedy is appropriate for 21 this area.

22 This, of course, doesn't mean that

23 actions outside of the CERCLA process, for whatever

24 reason, could not be taken, but specific to CERCLA,

25 there does not appear to be a reason for an action

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 26 1 at this site. -•"•Ml 2 MR. INGRAM: Terry Ingram.

3 I'd like to have somebody explain the

4 statement on page 7 that says, "The...Army expects

5 this alternative to meet the CERCLA requirements for

6 remedies. No Action is selected as the preferred

7 alternative as it protects human health and the

8 environment; provides an effective short- and

9 long-term solution..."

10 Where is the long-term solution?

11 Because this lead is out there, and it's going to

12 be gradually working into the environment. In what

13 way, we don't know.

14 MR. BAROUNIS: Based upon the results

15 of the risk assessment, that we do not have an

16 expectation that the concentrations of lead in the

17 soil at the site would exceed levels which would not

18 be protective. 19 MR. INGRAM: Protective of what?

20 MR. BAROUNIS: Protective of both human

21 health and the environment.

22 MR. INGRAM: It's already exceeded the

23 environmental criteria. 24 MR. BAROUNIS: The environmental

25 criteria that are fed into the equations and the

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 27 1 calculations which give us the ability to estimate

2 whether there's a risk or not do not suggest that

3 there would be a risk.

4 The factors that go into that

5 calculation include the area of concern and the

6 average lead concentration in that area.

7 One thing that's important to note is

8 that an ESV, an ecologic screening value, is a value

9 which, when it is reached, gives us a reason to look

10 more deeply with a more careful analysis at the site,

11 and that's what was done at this site.

12 Because there were individual hits

13 of lead, 3 out of 13, I believe, which exceeded

14 the ecologic screening value, that provided a

15 justification for doing a more — a more detailed

16 evaluation, taking into account the size of the area,

17 and evaluating what the average lead concentration is

18 versus the highest lead concentrations.

19 These kinds of results are congruent

20 with the protocols that we use to determine ecologic

21 risk. And based on the use of those protocols,

22 there does not appear to be a sufficiently high or

23 significant ecological risk and not a human health

24 risk.

25 MR. INGR7\M: We've got a concentrated

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 28 1 area of high lead that's hit three of those sections.

2 You could have done other samples where you hit more

3 of it. And the thallium was within one-hundredth of

4 a point, less than one percent difference from being

5 an ecological screening criteria with .99 to 1.00,

6 so both of those, and they're both in the top foot

7 of ground.

8 MR. BAROUNIS; Well, I would emphasize,

9 Terry, that we did look at all of the data; and

10 U.S. EPA and Illinois EPA concurred, both agencies

11 concurred that there was no human health risk and

12 no ecological risk. We accepted the results of the

13 Remedial Investigation when it was completed, and

14 we don't have any reason to go back and change our

15 assessment of those results.

16 MR. INGRAM: So you would allow a

17 house be built there and the kids playing on that

18 ground; is that right?

19 MR. CLARKE: No.

20 MR. INGRAM: No, I'm not asking — the

21 question — 22 MR. CLARKE: It's not intended for that

23 use. 24 MR. INGRAM: I don't care what it's

25 intended to do. I'm looking at down the road

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 29 1 sometime. Fish and Wildlife may sell it, just like

2 we have every one of these LUTCs -- 3 MR. CLARKE: Well, as a matter of —

4 MR. INGRAM: — and if they sell it, if

5 they build a house there, kids are going to be in it.

6 Are you going to leave it, "That's safe for them. Go

7 ahead, kids, play out in the lead"?

8 MS. FALCO: This is Charlene Falco from

9 Illinois EPA. 10 The soil chemistry results don't exceed

11 the human health screening criteria for residential

12 use, so —

13 MR. INGR7\M: Right now.

14 MS. FALCO: — those bullets aside,

15 yeah, you can put a house there.

16 MR. INGR7\M: But the bullets are there.

17 MS. FALCO: Yeah, the bullets are there.

18 MR. INGRAM: Let's get them out of

19 there. Let's get the point source out of there.

20 That would be the simplest solution. Just dig

21 up that ground, get the point source of the

22 contamination away from there, and then it would

23 gradually work its way up; but when you've got the

24 lead sitting there in those bullets, it's constantly

25 going to be refeeding the lead into the environment.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 30 1 MR. CLARKE: Mr. Ingram, we have

2 your statements, and we will respond to them in the

3 Responsiveness Summary. Repeating your position over

4 and over tonight will not change anything.

5 MR. INGRAM: No, I know that. I just --

6 I want -- I'm the only RAB member here, but I know

7 what the RAB has said in the past, and I'm just

8 trying to make sure everybody knows that. The RAB

9 is supposed to represent the public.

10 MR. CLARKE: It will be in the record.

11 MR. INGRAM: Duly noted.

12 MR. ANDERSON: Alan Anderson from the

13 U.S. Fish and Wildlife Service.

14 I'd like to know, if you can answer,

15 how did you determine the size of the area of

16 contamination? Because I've hunted — well, not

17 hunted, but I've used ranges for years and years and

18 years, and you always get bullets that go over the

19 backstop; and I'm just curious, because the picture

20 I saw, there was higher ground behind the range, and

21 has anybody looked back there?

22 MR. CLARKE: Yes, we did look back

23 there. 24 MR. ANDERSON: Okay.

25 MR. CLARKE: That is part of the

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 31 1 investigation. 2 MS. FALCO: Charlene from the EPA.

3 Craig, could you put up the map from

4 SAIC's report?

5 MR. HOBY: Sure.

6 This screen shows the sampling

7 locations, Alan, that were conducted as part of

8 the remedial investigation. So —

9 MR. ANDERSON: Is the top right on the

10 screen, inside that red box, the firing point?

11 MR. HOBY: Right. The firing point is

12 labeled at the top —

13 Lynn, if you would...

14 MR. EICH: The firing point is here,

15 shooting up there.

16 MR. HOBY: Shooting into the berm there.

17 MR. ANDERSON: Right, we're shooting

18 into a berm, but there's land behind the berm.

19 MR. EICH: The berm is here, and this

20 is the ground, right here.

21 MR. HOBY: Right. When you go back to

22 the photo, you see —

23 MR. ANDERSON: There's a ridge behind

24 there.

25 MR. HOBY: — yes, there's a ridge, and

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 32 1 then the slope to the river is behind there.

2 MR. ANDERSON: Right, and the berm is

3 only 7 to 10 foot, something like that. I"ve been

4 out there. But has anybody checked behind the berm,

5 into that bank, that sand bank?

6 MR. CLARKE: When you say "check," what

7 do you mean?

8 MR. ANDERSON: Check for lead bullets

9 and how many, the concentration?

10 MR. CLARKE: We have looked back there,

11 and I have found them back there, but not nearly as

12 many as right behind the targets.

13 MR. ANDERSON: I just was curious as

14 to what the concentration was in comparison. Because

15 if they're going to ask to have that site cleaned,

16 the berm, I'm not sure if that backstop — beyond

17 the backstop, how concentrated the lead is there.

18 Does that mean — or, is that enough

19 lead to have it cleaned, do we know?

20 MR. BAROUNIS: Well —

21 MR. CLARKE: The Army does not plan to

22 clean up the bullets. 23 MR. ANDERSON: 7\bsolutely, I understand.

24 MR. CLARKE: So, no matter whether

25 it — the berm or behind the berm.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 33 1 MR. ANDERSON: They're requesting to

2 clean up. 3 MR. CLARKE: They are.

4 MR. ANDERSON: Okay. The Fish and

5 Wildlife —

6 MR. CLARKE: But the Army finds no

7 legal driver to clean up the bullets. That's the

8 position of the Army.

9 MR. SMITH: But, John, at one time,

10 after our 2008 letter, there was a contract that was

11 in place to implement the Best Management Practices.

12 MR. CLARKE: That is correct.

13 MR. SMITH: And there was a change in

14 staff attorneys who had a different opinion, and now

15 that that — that effort was not conducted.

16 So, at one time, the Army did consider

17 and did agree with the position of the state, anyway,

18 that implementation of the Best Management Practices 19 for the area was appropriate.

20 MR, CLARKE: You are correct. When

21 the proposed plan reached the BRAC office and the

22 Environmental Law Division, we were told that the

23 Army would not fund that without a legal driver to

24 support the cleanup.

25 MR. SMITH: Well, the legal driver, I

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 34 1 would think, would be RCRA. The state or the Federal

2 Environmental Protection Agency could exercise the

3 RCRA authority and issue a violation notice based on

4 the past court cases.

5 Is that not an adequate legal driver?

6 MR. CLARKE: I couldn't tell you.

7 We would have to elevate that question to the

8 Environmental Law Division.

9 MR. BAROUNIS: This is Tom Barounis

10 again.

11 What Clarence said is correct. There

12 are potentially other avenues of approach. EPA's

13 point is that the site is not appropriate for a

14 CERCLA cleanup.

15 As I said before, this doesn't mean

16 that there might not be other agreements that could

17 be made to deal with concerns about things like

18 bullets remaining on the site. 19 MR. HOBY: My one response to your

20 concern as far as bullets behind the berm, the

21 sampling protocol that was implemented and the

22 results, the maximum concentration was detected

23 in the area that the most bullets were, came out at

24 380 part per million, whereas, from a remediation

25 contractor's perspective, the cleanup value is 400.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 35 1 So the site already meets — is clean

2 to what a remediation contractor would look for as

3 far as a guidance as to saying how clean does it need

4 to be. It needs to be 400 part per million. This

5 site here, where the most concentrated bullets are

6 currently is analyzing out at 380 part per million,

7 so that meets that criteria.

8 So I would — I would, just carrying

9 that logic forward to the area that you're — if

10 there's less bullets out there, I could only imagine

11 that the concentration therefore is even less; but

12 that does not address screening of the bullets. That

13 is an analysis of cleanup objectives on lead itself,

14 not necessarily the bullets.

15 MR. SMITH: That's focused primarily on

16 the chemical constituent of lead in the soil.

17 MR. HOBY: Correct.

18 MR. SMITH: It does not deal with the

19 point source of the lead projectiles that are out 20 there.

21 MR. HOBY: That's correct.

22 MR. ANDERSON: The one thing that 1 was

23 asking was, how did you determine how large was the

24 site, because there could be bullets further beyond

W 25 that berm.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 36 1 MR. HOBY: Right.

2 MR. ANDERSON: That was what I was 3 trying to ask.

4 MR. CLARKE: Walking in the field,

5 observing the bullets, the known boundaries of the

6 pistol range, all of those things were done to

7 determine the size of the site.

8 MR. ANDERSON: Okay. Thank you.

9 MS. FALCO: Alan, we'll do

10 investigations in phases, you know; and I can't

11 remember exactly the evolution of how this one came

12 about without looking back at the record; but if we

13 had seen concentrations that were very much higher -

14 MR. ANDERSON: Uh-huh (affirmative

15 response).

16 MS. FALCO: — we probably would have

17 gone out and taken some more samples or tried to

18 delineate further and would maybe have gone further

19 back at that point. 20 But, like Craig said, you go to the

21 area where the largest release or amount of release

22 is going to be and kind of base your sampling plan

23 off of that; and when we saw what the results were,

24 you know, there really didn't appear to be a reason

25 to do additional work after that point.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 37 1 MR. ANDERSON: Thank you.

2 MR. HOBY: Does anybody else have any

3 coinments or questions at this time?

4 MR. INGRAM: So it's the west end that's

5 180 feet from the Mississippi River?

6 MR. HOBY: I believe so, the west end

7 of the site.

8 MS. FALCO: I have a question for the

9 Army or for EQ.

10 MR. HOBY: Okay.

11 MS. FALCO: John, your opening remarks,

12 you mentioned the public comment period ran until

13 June 13th?

14 MR. CLARKE: Correct.

15 MS. FALCO: On the first page of the

16 Proposed Plan, it says June 15th. 1 just want to

17 clarify the ending date of the public comment period.

18 MR. HOBY: Yeah, 1 know it to be

19 May 14th through June 13th.

20 MS. FALCO: June 13th? The front —

21 you know, if this is the published Proposed Plan,

22 we probably have to extend that until the 15th.

23 MR. CLARKE: Agreed. There's no

24 problem there.

25 MS. FALCO: Okay.

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 38 1 MR. CLARKE: Ladies and gentlemen,

2 if there's no other questions, we will adjourn the 3 meeting and close the record.

4 Thank you for coming.

5 (The record was closed at 6:53 p.m.,

6 May 31, 2012.)

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563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Page 39 1 CERTIFICATE OF COURT REPORTER 2 3 I, Bev Herring-Black, a Certified Shorthand Reporter in and for the States of Iowa, Illinois and 4 Nevada, do hereby certify that the facts as stated on the face sheet hereto are true; that proceedings 5 of the Public Hearing held Thursday, May 31, 2012, commencing at 6:00 p.m., at Building 247, SVDA, 6 18935 B Street, Savanna, Illinois, consisting of the foregoing pages, is a true and complete transcription 7 of the record made by those present. 8 I further certify that I am neither attorney or counsel for, nor related to or employed by, any 9 of the parties involved in this hearing; and, further, that I am not a relative or employee of any of the 10 parties hereto or financially interested in said matter. 11 Dated this 4th day of June, 2012. 12 13 14 15 Bev Herring-Black 16 Certified Shorthand Reporter Iowa, Illinois and Nevada 17 Certified Realtime Reporter 2516 East 40th Street 18 Davenport, Iowa 52807 herringreporting0earthlink.net 19 563-355-0503 - 1-800-332-0503 20 21 22 23 24 25

563-355-0503 HERRING REPORTING SERVICES 800-332-0503 Site 32 - National Guard Pistol Range Record of Decision -l-A^ Environmental Quality Management, Inc. June 2014

ATTACHMENT B

WRITTEN COMMENTS - lEPA ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST, P.O. Box19276, SPRINGFIELD, ILLINOIS 62794-9276 • (217)782-2829 PATQUINN, GOVERNOR JOHN J. KIM, INTERIM DIRECTOR

217-524-1655

June 14, 2012

Mr. John E. Clarke Department of the Army Savanna Army Depot Activity DAIM-BD-N-SA 18935 B Street, Building 246 Savanna, Illinois 61704

Refer to: 0158100002—Carroll County Savanna Army Depot Activity Superfund/Technical Reports

Dear Mr. Clarke:

The purpose of this letter is to provide the Department of the Army (Army) with additional formal comments from the Illinois Environmental Protection Agency (Illinois EPA) on the Site 32 No-Action Proposed Plan for Site 32, the Former National Guard Pistol Range. Illinois EPA provided verbal comments for the record at the Proposed Plan Public Hearing that was held at the installation on Thursday, May 31, 2012.

Site 32 is a 0.40 acre small arms pistol range operated at the installation that was established in the mid-1950s and only operated for a few years, according to the Archives Search Report (ASR) for the Savanna Army Depot. Site 32 is contained in a parcel slated to be transferred to the United States Department of the Interior (DOI), Fish and Wildlife Service (USFWS) as a part of the Lost Mound Unit of the Upper Mississippi River National Wildlife Refuge. As the range is no longer in use, and has not been used for approximately 50 years, and is slated for transfer to the DOI USFWS, it does not appear to meet the definition of an inactive range identified at 35 Illinois Administrative Code, Subpart M, 726.301 (the Military Munitions Rule). The USFWS has also formally stated, in writing and oral comments that they have no intention to utilize Site 32 as a small arms range at any point in the future.

The Army conducted Remedial Investigations at Site 32, pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA or Superfund) to determine the nature and extent of contamination resulting from past operations as a small arms range. Site 32 exhibits chemical contamination from lead and other metals contained in military small arms ammunition at concentrations above naturally-occurring background levels, but at levels that do not trigger any CERCLA action, and at levels that are not likely to compromise the groundwater quality.

4302 N. Main Si., Rockford, IL 61103 (815)967-7760 9511 Harrison St., Des Plalnes, IL 60016 (847)294-4000 595 S. Stale, Elgin, IL 60123 (847)608-3131 5407 N. University St., Arbor 113, Peoria, IL61614 (309)693-5462 2125 S. First St., Champaign, IL 61820 (217)278-5800 2309 W. Main St., Suite 116, Morion, IL 62959 (618)993-7200 2009 Mall St., Collinrvllle, IL 62234 (618)346-51 20 100 W. Randolph, Suite 10-300, Chicago, IL 60601 (312)814-6026

PLEASE PRINT ON RECYCLED PAPER June 14, 2012 Formal Comments of the Illinois Environmental Protection Agency Regarding the Savanna Army Depot Site 32 Proposed Plan Page 2 of 6

However, Site 32 does contain, at the surface and up to two feet below the surface of the range backstop, lead and jacketed lead projectiles that are slowly corroding and releasing lead into the environment at a steady-state in a form that is readily bioavailable. Additionally, during the Remedial Investigation for Site 32, no sieve analysis of the backstop soils was performed to identify the particle size distribution and composition of any lead or other metals from military small arms ammunition that may be present in a metallic form. These two issues present serious concerns to Illinois EPA regarding the long-term protectiveness of a No Action Remedy at Site 32. It is Illinois EPA's position that these lead and jacketed lead projectiles pose a long terra ecological risk of biomagnification of lead and other heavy metals at Site 32, and is the basis of our non-concurrence of the Proposed Plan.

Lead projectiles in the environment, when exposed to air and water, transform to particulate lead and molecular lead species, such as lead oxide (PbO) and lead carbonate (PbCOs), with a total transformation from metallic lead to lead compounds being on the order of 100 to 300 years. Once lead becomes mobile in these lead compounds, it is readily transferred to biota, particularly soil and sediment invertebrates and terrestrial and aquatic plants, and eventually to higher trophic prey species (rabbits and squirrels), bioaccumulating and biomagnifying up the food chain. Elemental lead can also be utilized as grit by various avian prey species, depending on the sieve size, and can biomagnify up the food chain. This is a significant concern, due to the number of bald eagles and other avian predators that winter in the area of Site 32.

The National Oil and Hazardous Substances Pollution Contingency Plan (NOP, 40 Code of Federal Regulations (CFR) 300 - 399), which are the implementing regulations for CERCLA, defines that, for the purposes of the NCP, the threat of release is also a release (40 CFR 300.5).

In order to mitigate this threat of release of lead into the environment, Illinois EPA has provided comments to the Army numerous times m the past requesting that the best management practices (BMPs) for small arms ranges be implemented at Site 32 to address this yet undefined quantity of expended lead projectiles. Generally, this would require sifting the soil to remove expended bullets with appropriate disposal or reclamation, and mixing the soil with an amendment (a phosphate based fertilizer or metallic sulfide) to limit the solubility and mobility of the residual lead present.

Addressing the sites using BMPs would allow the sites to be managed in a manner consistent with good standards and practices throughout the small arms industry and would resolve future liability issues. Addressing Site 32 using BMPs would allow the future land transferees to manage the property in a manner consistent with their respective reuse plans.

Illinois EPA has re-considered regulatory drivers for such situations and provides the following comments in a final attempt to facilitate a solution for the Army, property transferees, and the State of Illinois.

There are essentially two definitions of solid waste; statutory and regulatory. The seminal judicial opinion and case that helped focus the status of expended lead shot as solid waste is that of the United States Comt of Appeals, Second Circuit, in Connecticut Coastal Fishermen's Association v. June 14, 2012 Formal Comments of the Ulinois Environmental Protection Agency Regarding the Savanna Army Depot Site 32 Proposed Plan W' Page 3 of 6 Remington Arms Company, Inc., E.I. DuPont de Nemours and Company, 989 F.2d 1305 (2d Cir. 1993). The Second Circuit Court of Appeals requested the United States Environmental Protection Agency (USEPA) to file m Amicus Curiae brief clarifying the statutory and regulatory defmitions of solid waste.

Pursuant to the Solid Waste Disposal Act (42 United States Code (USC) 6903), solid waste is defmed as; any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discarded material (42 USC 6903 (27)).

USEPA provides a determination in their Amicus, stating:

"...The literal meaning of "discarded" certainly can encompass shot and targets released into the environment and left to accumulate long after they have served their intended purpose. In other words, the ammunition and target fragments, if left on the ground indefinitely, eventually become discarded materials within the statutory definition of "solid waste." They still remain exempt from RCRA's comprehensive Subtitle C regulation, however, because EPA has not chosen to exercise its full regulatory authority under the statute..."

At what point materials become discarded has been a point addressed by the courts, and it was readily acknowledged by the Second Circuit Court of Appeals that there is no clear line regarding this. The Second Circuit Court of Appeals' opinion states,

"...Specifically, the EPA states that the materials are discarded because they have been "left to accumulate long cfter they have served their intended purpose. " Without deciding how long materials must accumulate before they become discarded - that is, when the shot is fired or at some later time - we agree that the lead shot and clay targets in Long Island Sound have accumulated long enough to be considered solid waste..."

In this instance, Illinois EPA, as a Resource Conservation and Recovery Act of 1976, as amended (RCRA) authorized State, has chosen to exercise its full regulatory authority in this matter. The Illinois Environmental Protection Act (Act, 415 Illinois Compiled Statutes (ILCS) 5/3.535) provides the statutory definition of solid waste, and is identical in substance to the definition in the Solid Waste Disposal Act. The regulatory definition of solid waste is found in 35 Illinois Administrative Code (lAC) 721.102 and is identical in substance to that of the implementing regulations of RCRA found at 40 CFR 260.2 and provides that a solid waste is any discarded material which is abandoned, with abandoned being characterized by being disposed, burned, incinerated, or accumulated, stored or treated before or in lieu of being abandoned. Illinois EPA interprets the Army's refusal to use BMPs to address residuals and the length of time that has passed since range operations have ceased (specifically, over fifty years for Site 32) as an indicator that the lead and jacketed lead projectiles present on the range have been discarded by the Army. Since the Army has no intention to ever retum to the site in question to address the waste materials, Illinois EPA has concluded that the Army has abandoned these materials as identified at 35 lAC 721.102. The range residuals, which are solid waste under the statutory provisions, also meet the regulatory definition of a solid waste also identified at 35 June 14, 2012 Formal Comments of the Illinois Environmental Protection Agency Regarding the Savanna Army Depot Site 32 Proposed Plan Page 4 of 6 -"•v

LAC 721.102 by virtue of being abandoned, and are now subject to foil regulation by the State of Illinois. This position is supported by USEPA Office of Solid Waste and Emergency Response (OSWER) Directive 9200.1-101, which states in Section 5.6 of the Directive:

"...the response occurs at a location other than an operational range, the response activity is not covered by the intended use exemptionfrom the regulatory definition of solid waste^. Therefore, the response activity would be subject to any applicable RCRA Subtitle C hazardous waste regulations if the material meets a listing description (see 40 CFR part 261, subpart D) or exhibits any of the characteristics of ignitability, corrosivity, reactivity, or toxicity under the criteria of 40 CFR parts 261.21, 261.22, 261.23 or 261.24... "

The Directive goes fijrther to state:

" ...Finally, nothing in RCRA or in EPA's Military Munitions Rule bars a State from exercising its own solid and hazardous waste authority over waste military munitions, including MEC/MC, regardless of whether they have adopted the Military Munitions Rule as part of their authorized RCRA program. DoD and/or other appropriate responsible parties have an obligation at "locations other than operational ranges" to clean up MEC/MC when required understate andfederal statutory authorities, and such cleanup may be subject to State and EPA oversight..."

It is now the Army's responsibility to manage that solid waste appropriately, including determining if the range residuals meet the definition of a hazardous waste as defined at 35 lAC 721.103 (the corresponding Illinois EPA RCRA regulation). Additionally, in my discussions with the USEPA Federal Facilities Restoration and Reuse Office (FFRRO), they stated that since the Range Rule has never been fmalized, that the exemption identified in 35 lAC 726.302(a)(1)(C) (40 CFR 266.202(a)(l)(iii)) ceases to exist once the a range becomes non-operational, as Site 32 is, the regulation of said range reverts to the status quo prior to the adoption of the 35 lAC and 40 CFR 266 Subpart M regulations.

The BMPs recommend that lead projectiles and particles be separated from soil and recovered so they could be recycled as scrap metal and not be a solid waste. The separated soil would need to be tested via TCLP. If hazardous, it would need to be managed accordingly as provided for in the State RCRA regulations; if the soil is non-hazardous and below remediation objectives, the soil could remain on site. If the soil is non-hazardous, but above risk-based objectives, the soil would require appropriate disposal or management with appropriate land use controls.

It is on this analysis of the apphcable statutes and regulations that Illinois EPA is basing our non- concurrence of the No Action Remedial Action at Site 32. If you should have any questions, need any

' The intended use exclusion from the definition of solid waste for recovery, collection, and on-range destruction of unexploded ordnance and munitions fragments during range clearance activities is limited to operational ranges as identified at 40 CFR 266.202(a)(l)(iii) (35 lAC 726.302(a)(1)(C)). June 14, 2012 Formal Comments of the Illinois Environmental Protection Agency Regarding the Savaima Army Depot Site 32 Proposed Plan Page 5 of 6 additional information, or would care to discuss this matter further, please contact me at 217-524-1655 or via electronic mail at [email protected].

Respect&lly,

Clarence L. Smith, Manager Federal Site Remediation Section Division of Remediation Management Bureau of Land

cc: Thomas Barounis United States Environmental Protection Agency Superfimd Division 77 West Jackson Boulevard, Mail Code SR-6J Chicago, Illinois 60604

Richard Kennard Department of the Army Corps of Engineers, Louisville District ATTO: CELRL-ED-E-C, Room 351 Post Office Box 59 Louisville, Kentucky 40201-0059

Leslie Roane Department of the Army Corps of Engineers, Louisville District ATTN: CELRL-ED-E-C, Room 351 Post OfTice Box 59 Louisville, Kentucky 40201-0059

Ed Britton Department of the Interior United States Fish and Wildlife Service Upper Mississippi River National Wildlife and Fish Refuge, Lost Mound Unit Post Office Box 336 Savanna, Illinois 61074 June 14, 2012 Formal Comments of the Illinois Environmental Protection Agency Regarding the Savanna Army Depot Site 32 Proposed Plan Page 6 of 6

Mike Coffey Department of the Interior United States Fish and Wildlife Service 1511 47*'' Avenue Moline, Illinois 61265

Valerie Njapa Illinois Department of Natural Resources Division of Resource Review and Coordination One Natural Resources Way Springfield, Illinois 62702-1271

Doug Maddox United States Environmental Protection Agency Federal Facilities Restoration and Reuse Office Ariel Rios Building 1220 Pennsylvania Avenue, NW Mail Code 5106P Washington, District of Columbia 20460 Site 32 - National Guard Pistol Range Record of Decision EQ Environmental Quality Management, Inc. June 2014

ATTACHMENT C

WRITTEN COMMENTS - USFWS United States Department of the Interior FISH AND WILDLIFE SERVICE Upper Mississippi River National Wildlife and Fish Refuge 7071 Rivcrview Road Thomson, Illinois 61285 May 30,2012 Mr. John Clarke SVDA, BRAC Environmental Coordinator U.S. Army, Savanna Army Depot Activity 18935 B Street Savanna, Illinois 61074

Dear Mr. Clarke:

This letter provides comments on the draft No Action Proposed Plan for Site 32, the National Guard Pistol Range, located at the Savanna Army Depot Activity, Savanna, Illinois. Site 32 lies within Parcel 9B that is proposed for transfer to the U.S. Fish and Wildlife Service (Service) as part of the Lost Mound Unit of the Upper Mississippi River National Wildlife and Fish Refuge (Refuge).

This closed pistol range has been a long standing site of concern for the Service. Our Regional Director Robyn Thorson \vrote to Colonel James Balocki, ACSIM BRAC Division Chief, on August 24,2007 and explained "The Service believes.. .the presence of lead fragments and bullets at the closed range presents an environmental threat because, over time, the lead will leach into the soil and move through the food chain...."

The Service continues to believe that a No Action Plan at Site 32 will not address the ecological risk present. This proposed plan identifies the Preferred Altemative to be a permanent solution that is protective of human health and the environment (page 6). However, the Army's environmental studies identified the presence of large amounts of lead bullets on the surface of the range and embankment (page 3). The Remedial Investigation showed that surface soil lead concentration exceeded the ecological screening value (page 3) and lead in the surface soil was identified as an ecological chemical of potential concern (page 6).

Lead in the environment is a nationally recognized ecological risk substantiated by many wildlife studies. These studies have shown that secondary lead poisoning is a major cause of bald eagle mortality. The acute poisoning occurs when eagles eat other wildlife that have lead in tlieir tissues. The Savanna Army Depot Activity is one of the largest bald eagle wintering areas on the Upper Mississippi River with hundreds of wintering eagles using this area on a daily basis for several months where Site 32 is located. Several small bird species occur at Site 32 including robins, mourning doves and meadowlarks that are eaten by bald eagles, other birds of prey and scavengers. The proposed plan does not appear to consider the exposure pathway and risks from wildlife ingesting the lead fragments. The pistol range site is small containing only 0.4 acre, but the large number of lead bullets and especially small fragments will continue to be an environmental hazard extending decades into the future. The Department of Army and Department of the Interior entered into a "Memorandum of Agreement Concerning Refuge Management and Property Transfers at the Savanna Army Depot Activity" in September 2003. This document identified that the Selection of Response Actions ensure that the remedy is protective of the environment (page 5). The Memorandum of Agreement also identified that Interior must be able to manage a parcel consistent with Interior's statutory responsibilities within the National Wildlife Refiige System Administration Act and the purposes for which the Refuge was established (page 12). The Service believes the No Action Plan is not protective of the environment and cannot manage this parcel consistent with our statutory responsibilities as long as the ecological risk is present.

Thank you for the opportunity to comment on this matter. If you need additional information, please contact me at 815-273-2732 ext 11. Sincerely,

Ed Britton District Manager cc; Tom Barounis, USEPA Charlene Falco, ILEPA Mike Coffey, USFWS Site 32 - National Guard Pistol Range Record of Decision m Environmental Quality Management, Inc. June 2014

ATTACHMENT D

WRITTEN COMMENTS - RAB Eagle Nature f dunciatlaas Ltd. I 300 East Hhskory»Steet, itpfeiiveri IL gllMii 8i5^94-i30fr 815^^4-2305

Board of mreciors June 1,2012 Sjte Terrencc N. tngram Mr. John Clarke, Apple River, IL BRAG Environmental CoonJinator, Joseph UllcBBeyk Savanna Araiy Depot Activity, HjckoryHilis, IL ,2nif t^ohfrsMdem Savanna, Illinois KicbudBriggs 61704 drangevllle, IL Secmary Angelina Kodriguei Dear Mr. Clarke, Cbica^.lL 7VcjaflAy Susan Eiuhet As you know 1 attended the public hearing on Site 32 that was conducted Scales Mound, IL Dihti^ati by EQM, Inc. last evening. 1 was very disappointed by the presentation when Richard Bagsier-CoHins Craig presented a whole list of stakeholders in the project and he never once men­ Galena, IL Lancc Fousl tioned the public, which is the biggest stakeholder, as we are paying the bills for Dekalb, IL the clean-up of this whole project and will be affected by diis project for many Thomas Gerard Holland Apple River. IL years if the Army goes through with the "No Action Proposed Plan" for this pro­ Paul Slowell ject. Elgin, IL Vicior Temple This is one of the easiest and cheapest contaminated sites on the post to be St. Charles, IL cleaned up. Scooping up the top 12 inches of soil and sifting it through a fine JohnVcrzal GlenEllyn. IL gravel screen and then replacing the soil would remove the point source of the Florence Cindy Waters contamination, which is the lead bullets that may be found in the ground. The Apple River, IL RAB board has discussed this issue in the past and has recommended that this be done before the land is turned over to anyone. I know that this is just part of a lar­ ger parcel that the Army plans to turn over the Fish & Wildlife Service. But if the IhoDiasC. I Elgin,IL Army does not clean it up the F&W Service will not accept it^ Also as I under­ stood the lEPA will insist that Site 32 be cleaned up before anything is done to it. Advimr^Bmrd Steve Anderson The whole site is only 0.4 acres so cleaning it up would not take very long Hartford, WI Dr. William Bowerman or cost very much. I and other members of the RAB board do not agree with the College Park. MD statement on page 3 that "This Proposed Plan indicates the No Action approach Billie D'JEnlremonl Las Vegas, NV will provide a permanent and comprehensive remedy for Site 32", Leaving the JohnOrigsby, Sr. copper-jacketed and unjacketed lead bullets in the ground will unnecessarily leave Canon, IL Robert Hatcher a point source of lead leaching into the environment for many years affecting who Brentwood, TN knows what species or people. The Array has the power to remove this point Yvonne Johnson Sycamore, IL source now for very little cost. Dr. Peter Justen Schaumbitrg, IL Roy Klehm As I stated at the hearing last night no environmental studies have been Barringlon, IL conducted on this site so we do not know what plants, insects, birds, mammals or Doris Mager Clyde, SC reptiles may be affected by this lead as it leaches into the soil. The ecological Dr. Daniel Raab screening level is just a number that some one picked out of the air. There is no Houston, TX Phyllis Sigafiis definitive proof that any amount below this number is safe or that the number has Apple River, IL any validity. It has been proven many times that just a few lead bb's picked up by Robert Torsberg Tlie Villages, PL a duck or an eagle can have a devastating effect on the health of that bird, perhaps to the point of death. Here we have much more lead than that. Page 2, Site 32 Comments We do not know what plants are growing at the site because no studies have been done. It could be that some plants grow there which are great feed for rabbits. The plants may pick up some of the lead that has leached into the soil and by constantly eating the plants the lead then accumulates in the rabbit's body. Then a predator; hawk, eagle, owl, coyote or fox would get that same lead when it would eat the rabbit. The bald eagle, a common nesting and wintering bird at the top of the food chain, which lives in the SAD, could then accumulate the most lead to the point that it may kill the bird or make it sterile.

It is such a small area that the USEPA states that it would not on the average have any affect. But it could possibly be the favorite feeding area for some species of animal starting the process of moving the lead through the environment to affect many species. Just because the area is small does not mean that it can be dismissed as having no effect. Because of the above possibility I cannot accept the statement on Page 6 "the screening value in this case overestimated the lead risk because the effec­ tive area of contamination is limited to a small area (0.4 acre) and exposure of wildlife and terrestrial plants to elevated concentrations of lead is limited spatially". No one knows for sure. This is an un- proven statement. If we are to going to err, let's err on side of safety and environmental health.

On page 6 the statement is made that "The site proposes no unacceptable risks to human health or the environment." Unacceptable to whom? I personally cannot accept it. The RAB, which is repre­ sentative of the public, cannot accept it The Fish & Wildlife Service cannot accept it. The lEPA can­ not accept it. Who else is there, the Array and EPA? It seems to me that they are a minority.

I and other members of the RAB take issue with line 4 on page 7, "The contaminant found in the media is not sufficiently toxic, mobile or concentrated to warrant any action." I cannot understand why this point source, solid lead bullets, are any less toxic than any lead that is found in chips of lead- based paint coming off a building?

This site. No. 32, the closed pistol range has been a long standing site of concern for the Fish and Wildlife Service. They are concerned about the lead bullets and bullet fiagments which can be and have been found at the site and are still there. They are the party which is scheduled to receive this site. If they won't take it without it first being cleaned up, who will?

1 and other members of the RAB board are asking the Army to scrap this proposed plan of No Action and do the simple thing of removing the point source of this lead pollution. Just pick up the soil, sift it, remove the bullets and fragments and then replace the soil.

Sincerely,

Tenence N. Ingram, President and Member, SAD Restoration Advisory Board Site 32 - National Guard Pistol Range Record of Decision Environmental Quality Management, Inc. June 2014

ATTACHMENT E

ARMY RESPONSE TO lEPA DEPARTMENT OF THE ARMY SAVANNA ARMY DEPOT ACTIVITY 18935 B STREET SAVANNAH 61074 REPLY TO ATTE^^•|ON OF:

BRAC Environmental Coordinator 6 July 2012

Mr. Clarence L. Smith, Manager Federal Site Remediation Section Dlinois Environmental Protection Agency 1021 North Grand Avenue East Springfield, Illinois 62794-9276

Dear Mr. Smith,

The Savanna Army Depot Activity (SVDA) is in receipt of your letter dated 14 June 2012 containing the Dlinois Environmental Protection Agency's (lEPA's) response to the SVDA Site 32 National Guard Pistol Range Proposed Plan. The Army has reviewed and considered those comments along with the comments that lEPA made at the SVDA Site 32 Proposed Plan public meeting held on 31 May 2012. Upon consideration, it is the Army's position that the No Further Action decision discussed in the Site 32 Proposed Plan is appropriate.

During the Remedial Investigation (RI), lead bullets from Site 32 were analyzed using the toxicity characteristic leaching procedure (TCLP) to simulate potential leaching to the w- groundwater aquifer. That test determined that the contaminant migration potential to groundwater was limited and, significantly, that the bullets are not a characteristic hazardous waste under 40 CFR Part 261, Subpart C.' The RI concluded that the bullets remaining at Site 32 do not pose a risk to human health or the environment. Based on the risk assessments, findings and conclusions in the RI Report, the Army determined that no further action was appropriate at Site 32.

Both the lEPA and the United States Environmental Protection Agency (USEPA) arrived at the same conclusion and provided concurrence letters to the final Remedial Investigation Report for Site 11, 32, and 82SS. The 22 December 2005 letter from EEPA specifically states, "Dlinois EPA provides no additional comment on Site 32 and, based upon the results of the risk assessments, concurs with the finding of no further action for this site."

The Army has reviewed the issues raised in lEPA's 14 June 2012 letter, and has determined that the Army's obligation to satisfy the requirements of CERCLA have been met.

lEPA's recent claim that the bullets remaining at Site 32 are a solid waste and should be removed using best management practices, even after lEPA having provided concurrence on the no further action finding, is unfounded. First, the bullets in question here are not a solid waste. As ammunition that was used during National Guard training {i.e., used for its intended purpose.

W ' The bullets also are not a listed hazardous waste under 40 CFR Part 261, Subpart D.

Printed On 1^^ Recycled Paper including use in training military personnel), it is not a solid waste. See 40 CFR § 266.202(a)(l)(i); 35 ILAC § 726.302(a)(1)(A).

Second, even if the bullets were a solid waste under applicable regulatory definition, there - is no regulatory driver to support their removal. There is no Illinois statute or regulation within the Illinois' EPA-delegated RCRA program that obligates the Army to clean up the bullets. Further, lEPA's reliance on the USEPA Office of Solid Waste and Emergency Response (OSWER) Directive 9200.1-101 is misplaced. That Directive deals specifically with munitions responses for Munitions and Explosives of Concern (MEC)^ and Munitions Constituents (MC), neither of which is present here.

For these reasons, the Army had determined that no further action remains the appropriate decision at Site 32.

Sincerely,

John E Clarke BRAC Environmental Coordinator Savanna Army Depot Activity Savanna, Illinois

' MEC is a term which distinguishes specific categories of military munitions that may pose unique explosives safety risks, including: (A) Unexploded Ordnance (UXO), as defined in 10 U.S.C. § 101(e)(5); (B) discarded military munitions (DMM), as defined in 10 U.S.C. § 2710(e)(2); or (C) munitions constituents (e.g., TNT, RDX), as defined in 10 U.S.C. § 2710(e)(3), present in high enough concentrations to pose an explosive hazard. Site 32 - National Guard Pistol Range Record of Decision m Environmental Quality Management, Inc. June 2014

ATTACHMENT F

HOUSEKEEPING ACTION COMPLETION REPORT FINAL COMPLETION REPORT Environmental Restoration Services Site 32 - National Guard Pistol Range Savanna Army Depot Activity Savanna, Illinois

Prepared for: /r U.S. Army Corps of Engineers Louisville District 600 Dr. M.L. King Jr. PI. Louisville, KY 40202-2232

Prepared bv:

Environmental Quality Management, Inc. 1800 Carillon Boulevard Cincinnati, Ohio 45240

March 2014 c FINAL COMPLETION REPORT

Environmental Restoration Services Site 32-National Guard Pistol Range Savanna Army Depot Activity Savanna, Illinois m

Prepared for:

U.S. Army Corps of Engineers Louisville District 600 Dr. M.L. King Jr. PI. Louisville, KY 40202-2232

Contract No. W912QR-04-D-0036 Task Order No. 0018

Prepared by: EIQ

Environmental Quality Management, Inc. 1800 Carillon Boulevard Cincinnati, Ohio 45240 (800) 229-7495 vmw.eqm.com

LQ FN: 030240.0018.02

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014

ACRONYMS AND ABBREVIATIONS

APP Accident Prevention Plan Army United States Department of Army bgs below ground surfaee CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CQCP Contractor Quality Control Plan CR Completion Report EQM Environmental Quality Management, Ine. ft foot or feet HA Housekeeping Action lEPA Illinois Environmental Proteetion Agency in. inch JULIE Joint Utility Locating Information for Excavators mg/1 milligrams per liter NFA No Further Action PWS Performance Work Statement RAB Restoration Advisory Board RCRA Resouree Conservation and Recovery Act ROD Record of Decision SSHP Site Safety and Health Plan SVDA Savanna Army Depot Activity TCLP Toxicity Characteristic Leaching Procedure U.S. United States US ACE United States Army Corps of Engineers USEPA United States Environmental Protection Agency USFWS United States Fish and Wildlife Service WP Work Plan

"W

Rev. No. 0 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

CONTENTS

Section Page Technical Review Certification iv 1. Project Description and Obj ectives 1-1 1.1 Project Description 1-1 1.1.1 Preparatory Activities 1-2 1.1.2 Field Activities 1-2 1.1.3 Concluding Activities 1-2 2. Project Preparatory Activities 2-1 2.1 Community Relations 2-1 2.2 Wastestream Sampling 2-1 2.3 Prior Notifications 2-1 2.4 Utility Clearance 2-1 2.5 Kick-off Meeting 2-2 3. Proj ect Field Activities 3-1 3.1 Site Preparation and Mobilization 3-1 3.2 C learing and Grubbing 3-1 3.3 Excavation 3-2 3.4 Load-out and Off-site Transportation of Waste 3-2 3.5 Grading 3-3 4. Waste Characterization, Transportation, and Disposal 4-1 4.1 Waste Characterization 4-1 4.2 Transportation 4-1 4.3 Disposal 4-2

APPENDICES

Appendix A Daily Field and Inspections Reports Appendix B Site Photographs Appendix C Wastestream Analytical Results, Profile, and Scale Tickets

TABLES

Page

Table 1. Disposal Quantities 4_2

iii Rev. No. 0 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

TECHNICAL REVIEW CERTIFICATION

COMPLETION REPORT

Contract No. W912QR-04-D-0036 Task Order No. 0018

I certify that this submittal has been reviewed in detail and is correct and in conformance with the contract Performance Work Statement, dated 24 March 2010.

03MAR14 William Thompson, Senior Techniem Advisor Date

03MAR14 G. Zody, P.E., Prdgf^ Manager Date

•w

IV Rev. No. 0 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

1. PROJECT DESCRIPTION AND OBJECTIVES

Environmental Quality Management, Inc. (EQM) has been tasked, under Contract Number W912QR-04-D-0036, Task Order 0018, by the U.S. Army Corps of Engineers (USACE), Louisville District, to complete environmental restoration services at Site 32, otherwise known as the National Guard Pistol Range, at the Savanna Army Depot Activity (SVDA) in Savanna, Illinois. EQM has prepared this Completion Report (CR) to document the Housekeeping Action (HA) specific to Site 32. EQM prepared an HA Work Plan in advance of the fieldwork. The HA Work Plan also included; • Attachment A - Contractor Quality Control Plan (CQCP) . Attachment B - Accident Prevention Plan (APP)

1.1 Project Description

EQM conducted the HA as part of the environmental restoration services at Site 32 of the SVDA. The USACE Performance Work Statement (PWS), dated 24 March 2010 and revised on 21 June 2013, incorporated herein by reference, provides detailed information about the site background, history, usage, and project requirements. The U.S. Army (Army), through the HA, intended to remove the spent bullets, slugs, and shot from the surface and shallow subsurface [i.e., 8-12 inches below ground surface (bgs)] as part of the closure of this site under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). This CR details the fieldwork undertaken following public comments received by the Army regarding the No Further Action (NFA) Proposed Plan, dated May 2012. All project work activities were completed in accordance with the requirements of the PWS and the approved final version of the HA Work Plan. The HA included the following tasks to remove residual bullets, slugs, and shot from the site:

1-1 Rev. No. 0 Site 32-National Guard Pistol Range Final Completion Report EQ Environmental Quality Management, Inc. March 2014

1.1.1 Preparatory Activities

EQM performed the following preparatory activities: . Prepared and submitted comprehensive work and safety plans to USAGE and Army for review. • Responded to review comments generated by the Army, the Illinois Environmental Protection Agency (lEPA), and the United States Environmental Protection Agency (USEPA) and submitted final planning documents to the Army and the regulators. . Collected and analyzed one soil sample to characterize the wastestream for off-site disposal. • Notified the utility location service to identify the nature and location of any underground utilities within the work zone.

1.1.2 Field Activities

EQM performed the following field activities: Mobilized labor and equipment to the site. Cleared and grubbed all trees and shrubs from within the work zone. Along with USAGE, established the horizontal limits [i.e., 15-feet (ft) wide and 87-ft along the slope and base of the embankment]. •-"N Excavated 6-12 inches (in.) of soil from the embankment and base. Visually inspected the subgrade soils to confirm the removal of spent bullets, slugs, and shot. Loaded-out, hauled, and disposed of the soils and entrained spent bullets, casings, slugs, and shot. Re-graded the disturbed area to match surrounding conditions and promote drainage. Demobilized manpower and equipment from the site.

1.1.3 Concluding Activities

EQM performed the following concluding activities: . Prepared and submitted a CR documenting the field activities and including analytical results, photographs, waste profiles, manifests, and daily reports. . Currently preparing a draft NFA Record of Decision (ROD) for review by USAGE, the Army, and regulators.

1.2 Housekeeping Action Objectives

The HA objectives were to: . Plan and receive approval of the planning documents from the Army, lEPA, and USEPA.

1-2 Rev. No. 0 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

Execute the HA to remove the spent bullets, slugs, and shot from the site. Restore the site to conditions acceptable to USAGE. Prepare, submit, and approve the final completion report and NFA ROD to document the HA and site closure.

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2. PROJECT PREPARATORY ACTIVITIES

In preparation for the field activities, EQM prepared the planning documents that included a specific Work Plan (WP), CQCP, and APP. EQM submitted these plans for review and approval by the USAGE, with courtesy copies provided to the lEPA and USEPA, Region 5.

2.1 Community Relations

The SVDA site is owned by the Army, and all community relations were coordinated through the current property owners. The Army authorized the HA in response to the comments received from the United States Fish and Wildlife Service (USFWS), lEPA, and SVDA Restoration Advisory Board (RAB) regarding the NFA Proposed Plan, dated May 2012.

•""Xn. 2.2 Wastestream Sampling

EQM collected and analyzed one soil sample to characterize the wastestream and obtain a disposal permit at an off-site commercial disposal facility. Additional details regarding the analytical results and profile are described in Section 4 and Appendix C of this report.

2.3 Prior Notifications

Prior to initiation of field activities, EQM notified Mr. Todd Knuth of the USAGE office at SVDA and determined a mutually agreeable timeframe for the completion of the field work. USAGE then notified representatives of lEPA and USEPA of the schedule for the field work.

2.4 Utility Clearance

Prior to any work involving the disturbance of soils associated with this project, EQM performed a utility clearance with the Joint Utility Locating Information for Excavators (JULIE). On 9 December 2013, JULIE issued Dig No. A3440719 to document the call. No underground

2-1 Rev. No. 0 Site 32-National Guard Pistol Range Final Completion Report EQi Environmental Quality Management, Inc. March 2014

W- utilities were identified as being in the work zone, nor were any underground utilities encountered in the work zone during the field activities.

2.5 Kick-off Meeting

On 12 December 2013, EQM conducted a preparatory phase inspection and met with a representative of USAGE to review procedures for conducting field activities. A copy of the checklist from that inspection and meeting is included in Appendix A.

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3. PROJECT FIELD ACTIVITIES

EQM completed the field activities as detailed in the approved WP. The daily and inspection reports EQM completed documenting the activities and associated photographs are located in Appendices A and C, respectively. The field activities were completed in 2 days, starting on 12 December 2013 and ending on 13 December 2013.

3.1 Site Preparation and Mobilization

EQM self-performed the excavation and load-out activities. On 12 December 2013, EQM mobilized manpower and equipment to the site. After arriving on site, EQM reviewed Site 32 with the USAGE to confirm in the field the extent of the proposed excavation along the embankment. EQM's Project Manager reviewed the WP and Site Safety and Health Plan (SSHP) with the field crew and also reviewed the current site conditions. EQM took delivery of a tracked, hydraulic excavator (Case 160) in the afternoon of 12 December 2013; delivery of the excavator was delayed by maintenance issues caused by cold weather conditions in northern Illinois. EQM noted that no underground utilities were marked within the work zone by JULIE. USAGE provided EQM with a key for the secure gate along River Road to access the site.

3.2 Clearing and Grubbing

On the afternoon of 12 December 2013, EQM used the excavator to clear and grub the sloped embankment and base of several small trees and shrubs. The trees were removed and placed off to the side of the embankment to form a brush pile.

3-1 Rev. No. 0 Site 32-Nationai Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014 w 3.3 Excavation

EQM made a shallow excavation of the surface and subgrade soils working from the top of the embankment down to its base. The excavator was equipped with a smooth bucket, allowing for uniform removal of the surface and shallow subgrade soil. The excavator's reach was sufficient to allow excavation of the embankment and base without having to track over the proposed work area. EQM first removed approximately 6 inches of soil from the entire embankment. EQM's Project Manager and a laborer then visually inspected the subsurface soil for the presence of bullets, slugs, casings, and/or shot. The embankment was predominately sandy soil and was not frozen despite the cold ambient temperature. EQM encountered areas along the embankment where the spent bullets were more concentrated and at a depth greater than 6 in. These areas were believed to have been immediately behind the static targets used by National Guard personnel. EQM made an additional excavation based on the visual presence of bullets. The maximum depth of the excavation was 12 in. into the embankment. EQM developed a windrow of excavated soil along the base of the embankment because it was too late in the day to load-out any of the excavated soils. The landfill closed before sufficient soil was excavated to constitute a full load for transport. On the morning of 13 December 2013, EQM loaded out the soil windrow and proceeded to excavate the surface soils underneath the windrow. EQM then perfomied a final inspection of the embankment and base, removed any spent bullets still present, and made an excavation in isolated pockets. In total, four loads of excavated soils were loaded out and hauled away. Representatives of the USFWS and USAGE were present during the excavation; no other visitors were present. The USFWS used photo documentation of previous site visits to verify the lateral extent of the final excavation included those areas where USFWS encountered bullets in the surface and shallow sub-surface soil.

3.4 Load-out and Off-site Transportation of Waste

EQM subcontracted the transportation of the waste to Bodine Services of Peoria, LLC (Bodine) and McGimpsey Trucking (McGimpsey). EQM was able to directly load each truck with excavated soil from the embankment by backing the semi-tractors across the field and to a

3-2 Rev. No. 0 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014 location adjacent to the embankment. On 13 December 2013, EQM completed the load-out and transportation of all the waste.

3.5 Grading

After the final inspection, EQM graded the disturbed area using the bucket of the exeavator on the sloped embankment. EQM repeatedly tracked over the disturbed area at the base of the embankment to eompact the soil. No backfill was imported or needed to match the surrounding grade.

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4. WASTE CHARACTERIZATION, TRANSPORTATION, AND DISPOSAL

EQM contracted the disposal of all wastes generated through the field activities to an off- site commereial facility. Copies of the wastestream characterization data, profile, manifests, and scale tickets are loeated in Appendix C.

4.1 Waste Characterization

On 29 November 2013, EQM collected a sample of the embankment soils. EQM collected five soil aliquots from along the entire length of the embankment. Eaeh aliquot was colleeted from the 0- to 6-in.-depth interval. EQM composited the five soil aliquots to generate one composite sample for Toxicity Characteristic Leaching Procedure (TCLP) metals analysis per the Resource Conservation and Recovery Act (RCRA). EQM delivered the soil sample to a representative of Test America Laboratories for express delivery to its laboratory in Cedar Rapids, Iowa. Test America Laboratories issued the results for Sample 310-20598-1 in its report dated 3 December 2013. The TCLP RCRA data supported the characterization of the waste as a RCRA non-hazardous waste. Lead was the only metal detected in the TCLP extract; the concentration was 0.286 milligram per liter (mg/L), well below the regulatory threshold of 5.0 mg/L. EQM completed a wastestream profile from Waste Management, Inc., based on the analytical results, a physical description of the wastestream, and generator knowledge. Waste Management, Inc., approved the profile and issued Profile No. 6079791L to document its approval for disposal at Prairie Hill Recycling & Disposal Facility. Copies of the laboratory report and wastestream profile form are located in Appendix C.

4.2 Transportation

EQM subcontraeted the transportation of the excavated soils to Bodine and MeGimpsey.

%W*-' Both companies hauled the wastestream in semi-tractors equipped with aluminum dump trailers

4-1 Rev. No. 0 Site 32-National Guard Pistol Range Final Completion Report Eg Environmental Quality Management, Inc. March 2014 capable of a typical 24-ton payload. EQM provided the driver of each load with a waste manifest to document and track each load. Each truck was scaled at the disposal facility. Four loads were hauled on 13 December 2013. All loads were shipped, received, and accepted at the disposal facility; no loads were rejected. Bodine and MeGimpsey both reported that no incidents occurred while traveling to and from the disposal facility nor while dumping at the disposal facility.

4.3 Disposal

EQM subcontracted the disposal of the embankment soils to the Prairie Hill RDF, a RCRA subtitle D landfill operated by Waste Management, Inc., in Morrison, Illinois. A total of 70.36 tons of the wastestream was disposed of at Prairie Hill RDF on 13 December 2013 as a RCRA non-hazardous, Illinois non-special, waste under Profile No. 607979IL. Table 1 summarizes the quantity of material disposed.

Table 1. Disposal Quanti ies Date Scale Ticket Tonnage 13 Dec 323871 18.05 13 Dec 323885 14.97 13 Dec 323929 21.35 13 Dec 323944 15.99 Total 70.36

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APPENDIX A

DAILY FIELD AND INSPECTIONS REPORTS

March 2014 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

PREPARATORY PHASE CHECKLIST SPEC SECTION 12/12 13 (CONTINUED ON SECOND PAGE) NA CONTRACT NO DEFINABLE FEATURE OF WORK SCHEDULE ACT NO. W912QR-04-D-0036. TO Housekeeping Action - Site 32 NA NA 0018 GO\'ERNMENT REP NOTIFIED 48 HOURS IN ADVANCE:

COMPAmVGOVERNMENT u NAME 5/5 u CnigHobr Flrojcct Muigei EQ as EQ 0. DwtyCrites Opcntor -J u Scott Boyer Opentor EQ z. USACEQCRcp GovcroBeot.USACE O

RE\TEW SUBMITTALS ANDOR SUBMITTAL REGISTER. HAVE ALL SUBMTTTALS BEEN APPROS'ED?

IF NO. ^HAT ITEMS HAVENOT BEEN SUBMTTTED?

< ARE ALL MATERIALS ON HAND? i: IF NO. R-HAT ITEMS ARE MISSING? ica u 5/5 CHECK APFRON'ED SUBMITTALS AGAINST DELIVERED MATERIAL (THIS SHOULD BE DONE AS MATERIAL ARRIVES )

COMMENTS: No oMcmli to be delivand ta ic«p« of wofk.

ARE IMTERIALS STORED PROPERLY?

IF NO. WHAT ACTION IS TAKEN? < u a! < U) 02 O < i-

RFVTEW EACH PARAGRAPH OF SPECmCATTONS.

C/5

g DISCUSS PROCEDURE FOR ACCOMPUSHINO THE WORK. Sbtlbv eK•^«tioa of wab excavator fi>llowed by vonal itupecfioa of sab>gnde soib for the pmence ofbuUeis. < U (Oil will be tenoveil nntil the incpectioB* dcteraiiae the bujlett have been removed. u

0. 5/5 CLARIFY ANY DDTERENCES.

EQ may uu1 rnbte-l*. badcEn to tiaiiab ascatatcd matatial out to tba loatlway. Foi loa^u iFtbc tntdo cauail (ct toIbt bom ana 10 allow Ibr dinci loadonl. If fwceaaaiy, EQ arill stoi^blo watta mitcritl Ott plaMic vaqpeea

ENSLUE PmjMINARY WORK IS CORRECT AND PERMTS ARE ON FILE Duposal pamal at Ptaalo HtU laodfiU is atlho. JULIE oomaotad -oo olilain pmon b> piopowd woA loo.

IF NOT. HHAT ACTION IS TAKEN? JULIE <1I{ niiiibor lo docmml can is AJ44071S. ii

5/5 H — IDENnFY TEST TO BE FERFOR.\IED, FREQUENCV, AND BY WHOM. Comimoo. nmal iospaclio. by EQ. PM and USACE'i QC np acrosa Iba widdi of lb. mnbaokmoot

March 2014 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

Afld 10 iuM* the btie of the eobukmeitt

WHEN REQUIRED?

WHERE REQUIRED?

RE\TEW TESTTNO PLAN

HAS TEST FACHJHES BEEN APPROVED?

ACnVtlY HAZARD ANALYSIS APPROVED? YES X NO

REVIEW APPLICABLE PORTION OF EM 383-1.1. Cold «-cnber coodilioos - nqsin ngahi wanna| in heeled nhiclet. No biotogkel tl 1 at this ttne ofyear. Snow makes bt lacreascd > Trip'slip hazarl Scope ofwoifcrcqnaies close coordtnatioa oftbe opentioa oftbecxca\-atiooai)d tbeiaspectioBoftfac nh-padc soils. Risks to gtondpcnoaael while excavatora opentiag will U < Be maoaged by close verhal commBSicetsoa with equpment operator tad groaaJ penoaKl Groitod personoel to keep proper distaore d-omexctvvtor while ia operatioa and to tocated theosehTi C/} Wkhis the operators field of visioiL

USACE/SNDA COMMENTS DURINO MEEIINO.

t/5 laiqsectioBofihe base oftheembankmeal&r bullets to be included. H Z. u 8 (Jz

u

OTHER ITEMS OR REMARKS: oa: t/5

o

DATE U,12/13

OC MANAGER

March 2014 Site 32-National Guard Pistol Range Final Completion Report EQ Environmental Quality Management, Inc. March 2014 w DAILY CONSTRUCTION QUALITY CONTROL REPORT

PROJECT: HOUSEKEEPING ACTION DATE: Decl2,2013 SVDA SITE 32

CONTRACT NO: W912QR-04-D-0036, TO # 0018 REPORT NO.: 001

WEATHER: Cold & Overcast, no wind TEMP: 15 °F PRECIP: None

SITE CONDITIONS AND PORTION OF THE DAY SUITABLE FOR WORK: Work diuing dayliglit horns; site conditions are acceptable, 2-3 inches of snow cover, minimal frost in siuface soils.

PHASES OF CONSTRUCTION IN PROGRESS: NODES CONTRACTOR or DESCRIPTION SUBCONTRACTOR

EQM Mobilized field crew and equipment to site. Arrived at 8:45 am. Reviewed site conditions with field crew. No JULIE markings since no utilities were identified as in the near-by area - JULIE ID number A3440719. Laid out proposed removal area with USACE rep. Subcontractor (Bodine) aiiived at 10:30 am. Subcontractor (Titan Rental) repotted problems in starting excavator prior to deliveiing the machine due to the cold weather; Titan replaced fiiel filter and used cold weather diesei fiiel Ueatment as an additive to the fiiel. Excavator airived at 2:15 pm. Timing such that is was too late in the day to haul any waste to the landfill, so Bodine left at 2:30 pm; will renim at 7:00 am on Dec 13, 2013.

Cleared the sloped embankment of trees and small slunbs using the excavator. Created a small brush pile of cleared tr ees and located it off to the west of the embankment. Perfomied initial - shallow excavation of embankment. Soil was predominately sand covered by leaf litter. Worked the embankment from top to bottom, removing 6-8 inches of soil. Created a wind-row of the excavated soil along the base of the embankment. Visually inspected the exposed sub-grade soils for the presence of bullets, slugs and shot. Encoimtered several areas where bullets were concentrated; perfomied additional excavation to approximate depth of 12 inches in order to remove the bullets and associated soils from those specific areas.

Completed work at 4:15 prn.

MATERIAL and/or EQUIPMENT DELIVERED TO SITE:

Case 160 excavator delivered in the afternoon.

March 2014 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

Page 2 of 4 INSPECTIONS PREPARATORY: Specification Section: Aie notes attached? X YES NO If NO explain: LNITIAL: Specification Section: Aie notes attached? YES _X_ NO If NO explain: FOLLOW UP: Specification Section: Are notes attached? YES X NO If NO explain:

NODES DESCRIPTION

ARE ANY DEFICIENCIES NOTED IN FOLLOW UP INSPECTIONS? YES X NO If YES, explain:

DEnCIENCIES CORRECTED TfflS DATE: DEFICIENCY QC REPORT DESCRIPTION NUMBER REFERENCE NA None

TESTS PERFORMED: SPECIFICATION TEST AND RESULT SECTION NA No tests perfonued in the field.

Are Test Results attached? YES X_ NO IF NO, explain: No tests required.

March 2014 Site 32-National Guard Pistol Range Final Completion Report EQ Environmental Quality Management, Inc. March 2014

Page 3 of 4 VERBAL INSTRUCTIONS RECEIVED: None

CHANGED CONDITIONS/DELAYS/CONFLICTS ENCOUNTERED: Noue

Did a Delay or Work Stoppage Occur Today? X_ YES NO If yes, explain: The delay was only an operational delay in delivery of equipineiit; no contractual or stoppage implications.

Has Anything Developed in the Work Wliich May Lead to a Change or Finduig of Fact? ^N0_ If yes, explain:

SAFETY:

Safety review/briefing conducted. PFE required includes hard hat, liigli visibihty vest, safety glasses, gloves, steel toe work boots. Cold weather conditions - requhe rest in die heated vehicles for wanning.

Operation of excavation and performing visual inspection of the excavation in coordination with the active excavation—risks to groimd persormel reviewed.

REMARKS:

Tire report is complete and correct and all materials and equipment used and work performed dming tliis reporting period are in compliance with the contract plans and specifications except as noted above.

I2/I2/I3

Contractor's Approved Authorized Representative Date

GOVERNMENT QUALITY ASSURANCE REPORT QUALITY ASSURANCE REPRESENTATIVE'S REMARKS AND/OR EXCEPTIONS TO THE REPORT

DATE SIGNATURE OF GOVERNMENT QUALITY ASSURANCE REPRESENTATIVE w

March 2014 Site 32-National Guard Pistol Range Final Completion Report W) Environmental Quality Management, Inc. March 2014

Page 4 of 4 MAN HOUR AND EQUIPMENT REPORT

Contract: W912QR-04-D-0036, TO # 0018 Report Number: 001 Date: Dec 12, 2013 Prime Contractor: Enviiomnental Quality Management, Lie.

Classification # Persons Hoiu-s T>-pe ofEquipinent ft Active / Idle Project Maiiajier I 10 Pick-up Truck 1 Active Operator 2 10 Case 160 Excavator 1 Active

Subconlinctor: Bodlnf MANPOWER EQUIPMENT

Classification U Persons Hours Ts-pe of Equipment tt Arrive /Idle Driver 1 8 Semi-tractor rsith dump trailer 1 Active

Subcontractor: Timn MANPOWER EQUIPMENT

tt Pei-sons Hours Tvpe of Equipment tt Active / Idle Driver 1 4 Semi-tractor w/ lowboy 1 Active

Total this Date: 42 Total hours Previous Report: 0 Total Hours to Date: 42 Total Man Hours this Month: 42

March 2014 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

DAILY CONSTRUCTION QUALITY CONTROL REPORT

PROJECT: HOUSEKEEPING ACTION DATE: Decl3,2013 SVDA SITE 32

CONTRACT NO: W912QR-04-D-0036, TO # 0018 REPORT NO.: 002

WEATHER: Cold & Patlly Cloudy, no wind TEMP: 8-15 °F PRECIP: None

SITE CONDITIONS AND PORTION OF THE DAY SUITABLE FOR WORK: Work dming dayliglit horns; site conditions are acceptable, 2-3 inches of snow cover, ininimal frost in suiface soils.

PHASES OF CONSTRUCTION IN PROGRESS: NODES CONTRACTOR or DESCRIPTION SUBCONTRACTOR

EQM Started at 7:00 am. Despite being cold, excavator stalled and was allowed to warm-up for 30 minutes.

Bodine anived at 7:00 am. EQM loaded out excavated soils from the windrow at the base of the embankment. A second semi-tractor with dump tiailer from McGimpsey Trucking anived at 7:45 am and was loaded with excavated soils. EQM perfoiiued additional excavation of the soils fr om along the base of the embankment and area undemeath the windrowed soils now gone. Repeated the W visual inspection of subgrade soils. Representatives of USACE and USFWS were present.

Loaded out two additional loads of soils at 10:45 am and 11:30 am. Scraped the bucket of the excavator to remove soils adliermg to it; soils were loaded out. Peifonued one last visual inspection, removuig any encountered bullets by hand.

Used the excavator bucket to rougli grade the embankment soils and then track-walked the base of the embankment. Tracked the excavator to an area outside of the secured gate at river road.

Completed work at 12:15 pm.

MATERIAL and/or EQUIPMENT DELIVERED TO SITE:

None - 4 semi loads of excavated soil hauled to Prairie Hill Landfill, Monison, IL.

March 2014 Site 32-National Guard Pistol Range Final Completion Report EXj Environmental Quality Management, Inc. March 2014

Page 2 of 4 INSPECTIONS PREPARATORY: Specification Section: Aie notes attached? YES _X _NO If NO explain: Completed on 12/12/13 INITIAL: Specification Section: Aie notes attached? _X_ YES __NO If NO explain: FOLLOW UP: Specification Section: Aie notes attached? YES X NO If NO explain:

NODES DESCRIPTION

ARE ANY DEFICIENCIES NOTED IN FOLLOW UP INSPECTIONS? YES X NO If YES, explain:

DEFICIENCIES CORRECTED THIS DATE: DEFICIENCY QC REPORT DESCRIPTION NUMBER REFERENCE NA None

TESTS PERFORMED: SPECIFICATION TEST AND RESULT SECTION NA No tests perfonued in the field.

Aie Test Results attached? YES X_ NO IF NO, explain: No tests leqnired.

March 2014 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

Paee 2 of 4 INSPECTIONS PREPARATORY: Specification Section: Are notes attached? _YES _X _NO If NO explain: Completed on 12/12/13 INITIAL: Specification Section: Are notes attached? _X_ YES NO If NO explain: FOLLOW UP: Specification Section: Are notes attached? YES X NO If NO explain:

NODES DESCRIPTION

ARE ANY DEnCIENCIES NOTED IN FOLLOW UP INSPECTIONS? YES X NO If YES, explain:

DEEICIENCIES CORRECTED TfflS DATE: DEFICIENCY QC REPORT DESCRIPTION NUMBER REFERENCE NA None

TESTS PERFORMED: SPECIFICATION TEST AND RESULT SECTION NA No tests perfonned in the field.

March 2014 Site 32-National Guard Pistol Range Final Completion Report EQ Environmental Quality Management, Inc. March 2014

Page 4 of 4 MAN HOUR AND EQUffMENT REPORT

Contract: W912QR-04-D-0036, TO # 0018 Report Niuuber: 002 Date: Dec 13, 2013 Prime Coutiactor: Enviromiiental Quality Management, Lie.

MANPOWER EOUIPMENT ClassUlcation tt Persons Hours T>-pe of Equipment Active / Idle Project Manager 1 8 Pick-up Truck 1 Active Operator 2 10 Case 160 Excavator 1 Active

Snbcontractor: Bodine MANPOWER EQUIPMENT

Classification # Persons Hours Tspe of Equipment # Active /Idle Driver i 8 Semi-tractor with dump trailer i Active

Subcontrnctor: McGimpw Tnicking MANPOWER EQUIPMENT

Classification n Persons Hours Type of Equipment # Active / Idle Driver 1 8 Semi-tractor with dump trailer 1 Active

Total tliis Date: 44 Total hours Previous Report: 42 Total Hoius to Date: 86 Total Man Hours tliis Month: 86

March 2014 Site 32-National Guard Pistol Range Final Completion Report EQ Environmental Quality Management, Inc. March 2014

SPEC SECnON INITIAL PHASE CHECKLIST NA 12'13/U CONTRACT NO DEFINABLE FEAUmE OF WORX SCHEDULE ACT NO. W912QR-

COMPANY/GOVERNMENT i- Cnig Hoby Project M«uger EQ

EQ uX Dusty Cf lies Operelor cc cu Scon Beyer Opertior EQ

u QCRep

O

IDENTIFY FULL COMPLIANCE WITH PROCEDURES IDENTIFIED AT PREPARATORY. COORDINATE PLANS. SPECIHCATIONS. AND SUBMITTALS.

COMMENTS; Tracks arc able to be directly loaded by excirator at the enbankmeol; oo double biodliii^'stocl^ reqwred.

ENSURE PRELIMINARY WORK IS COMPLETE AND CORRECT. IF NOT. WHAT ACTION IS TAKEN? > All permits are ia place. Waste material is acceptable to the ditpotal ftcility. CC

ii• s? u cc (1.

ESTABLISH LEVEL OF WORKMANSHIF.

WHERE IS WORK LOCATED? Site 32 at S\'DA

X X < s IS SAMPLE PANEL REQUIRED? YES NO X X WILL THE INITIAL WORK BE CONSIDERED AS A SAMPLE? YE% NO i (IF YES, MAINTAIN IN PRESENT CONDITION AS LONG AS POSSIBLE AND DESCRIBE LOCATION OF SAMPLE)

RESOLVE ANY DIFFERENCES.

COMMENTS: Nooe o H U O X Lai CC

March 2014 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

RRIEW JOB CONDITIONS USING EM 38S.M AND JOB HAZASD ANALYSIS

PPE ta we by ficU emr Wni^ a vehkkt w Deeded No if H

OTHER ITEMS OA REMAIUCS a Ui X H O

QC MANAGER

March 2014 Site 32-Nationai Guard Pistol Range Final Coinpletion Report Environmental Quality Management, Inc. March 2014

W

APPENDIX B

SITE PHOTOGRAPHS

March 7014 Site 32-National Guard Pistol Range Final Completion Report o Environmental Quality Management, Inc. March 2014

Figure 1. Clearing embankment of trees and shrubs

Figure 2, Initial excavation of embankment, with soils O windrowed along the base of the embankment

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014

Figure 3. Cluster of bullets embedded in shallow embankment soils

Figure 4. Load-out of embankment soils and bullets

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014

Figure 5. View of completed excavation Tfn

Figure 6. View of excavation after compacting O the base of the slope via tracking

March 2014 Site 32-Nationai Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

APPENDIX C

WASTESTREAM ANALYTICAL RESULTS, PROFILE, AND SCALE TICKETS

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014 TestAmerica

THE LEADER IN ENVIRONMENTAL TESTING .'f •

ANALYTICAL REPORT TestAmerica Laboratories, Inc. TestAmerica Cedar Falls 704 Enterprise Drive Cedar Falls, IA 50613 Tel: (319)277-2401 TestAmerica Job ID: 310-20598-1 TestAmerica Sample Delivery Group: 030240.0018.02 13 Client Project/Site: SVDA Site 32 For: Environmental Quality Mgt., Inc. 12721 Wblf Road Geneseo, Illinois 61254

Attn: Mr. Craig Hoby

Authorized for release by: 12/3/2013 10:03:24 AM Angela Muehling, Project Manager I (319)277-2401 [email protected]

This rsport has been electronically signed and authorized by the signatory. Electronic signature is intended to be the legally binding equivalent of a traditionally handwritten signature

Results relate only to the items tested and the sample(s) as received by the laboratory

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014

Client Environmental Quality Mgt, Inc. TestAmerIca Job ID: 310-20598-1 Project/Slte: SVDA Site 32 SDG: 030240.0018.02 Table of Contents Cover Page i Table of Contents 2 isiir Case Narrative 3 Sample Summary 4 Client Sample Results 5 u Chronicle 6 Definitions 7 Certification Summary 8 Method Summary 9 Chain of Custody 10 Receipt Checklists 12

o

TestAmerIca Cedar Falls Page 2 of 12 12/3/2013

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014

Case Narrative Client Environmental Quality Mgt, Inc. TestAmerica Job ID: 310-20598-1 Project/Site: SVDA Site 32 SDG: 030240.0018.02

Job ID: 310-20598-1 Laboratory: TestAmerica Cedar Falls

Narraave Job Narrative 310-20598-1

Comments No addillonal comments.

Receipt The sample was received on 11/26/2013 9:50 AM; the sample arrived In good condition, property presen«d and, where required, on Ice. The temperature of the cooler at recelpl was 0.5° C.

Metals No analytical or quality Issues were noted. I4J Organic Prep Method(s) 1311: EPA Method 1311 requires the temperature of the room to be maintained at 21 to 25 degrees Celsius. For batch 32871, a temperature excursion of 19.3 was noted. (310-20598-1 DU), Range Soil (310-20598-1)

No other analytical or quality Issues were noted.

o- TestAmerica Cedar Falls o Page 3 of 12 12/3/2013

March 2014 Site 32-National Guard Pistol Range Final Completion Report EQ Environmental Quality Management, Inc. March 2014

Sample Summary Client Environmental Quality Mgt, Inc. TestAmerica Job ID: 310-20598-1 Project/Site: SVDA Site 32 SCX3: 030240.0018.02

Lal>S«npie ID CMntSampI* ID Coliecttd Received 310-20598-1 Range Sol Sold 11/25/13 12:05 11/26^ 309:50

TestAmerica Cedar Falls

Page 4 of 12 12/3/2013 c

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014

Client Sample Results Client Environmental Quality Mgt, Inc. TestAmerlca Job ID: 310-20598-1 Project/Site: SVDA Site 32 SDG: 030240.0018.02

Client Sample ID: Range Soil Lab Sample ID: 310-20598-1 Date Collected; 11/25/13 12:05 Matrix: Solid Date Received: 11/26/13 09:50

Method: 601OC - Metals (ICP) - TCLP Analyte Result Quaitfter RL IVDL Unit D Prepared Analyzed DUPac Arsenic <0.300 0.300 mg/L 12rt)2/13 10:11 12/02/1316:39 1 Barium <0.500 0.500 mg/L 12/02/1310:11 12/02/1319:39 1 Cadmium <0.0200 0.0200 mg/L 12AJ2/13 10:11 12/02/1319:39 1 Chfomtum <0.0200 0.0200 mg/L 12A)2/13 10:11 12/02d3 19:39 1 Lead 0.286 0.100 mg/L 12A)2/13 10:11 12/02d319:39 1 Selenium <0.150 0.150 mg/L 12^)2/1310:11 12/02/1319:39 1 Siver <0.0200 0.0200 mg/L 12/02/1310:11 12/02d3 19:39 1

Method: 7470A • Mercury (CVAA) - TCLP Analyte Resutt cuaimer RL MDL Untt D Prepared Analyzed on Fee Mercury <0.00200 0.00200 mg/L 11/27/1311:67 11/27/1316:04 1 .a

TestAmerlca Cedar Falls

Page 5 of 12 12/3/2013

March 2014 Site 32-Nationa! Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014 o Lab Chronicle Client Environmental Quality Mgt, Inc. TestAmerIca Job ID: 310-20598-1 Project/Site: SVDA Site 32 SDG: 030240.0018.02

Client Sample ID; Range Soil Lab Sample ID: 310-20598-1 Date Collected: 11/25/13 12:05 Matrix: Solid Date Received: 11/26/13 09:50

Batch Batch Oilutlon Batch Spared Prep Type Type Method Run Factor Number orAnaly2ed Analyst Lab TCLP Leach 1311 32871 11/26/1316:20 JLO TAL CF TCLP Prep 7470A 32970 11/27/1311:57 OAD TALCF TCLP Analysis 7470A 1 33005 11/27/1316:04 OAD TALCF TCLP Leach 1311 32871 11/26/1316:20 JLD TALCF TCLP Prep 301OA 33133 12A)2/1310:11 SAV TALCF TCLP Analysis 601OC 1 33222 12A>2n3 19:39 OAD TALCF

Laboratory References: TAL CF » TestAmerica Cedar Fals, 704 Enteipr»* Drive, Cedar Falls, lA 50813. TEL (318)277-2401

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TestAmerica Cedar Falls

Page 6 of 12 12/3/2013

March 2014 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

Definitions/Glossary Client Environmental Quality Mgt, Inc. TestAmerica Job ID: 310-20598-1 Project/Site: SVDA Site 32 SDG: 030240.0018.02

Glossary

These commonly used abbreviations may or may not be present In tNsreport Listed under the '0' colurm to desi^ate that the result is reported on a dry weight basis %R Percent Recovery CNF Contains no Free Lic^id DER Duf^cate error ratio (normaliaed absolute difference) Oil Fsc Dilution Factor DL. RA RE, IN Indcates a Dilution, Re-analysis, Re-extraction, or additional Inidal metalsfenlon anelyt^s of die sample DLC Decision level concentration MDA Minimum detectable activity EDL Estimated Detection Limit MDC Minimum detectable omcentratlon MOL Method Detection Limit ML Minimum Level (Dioxin) NO Not Calculated rr"] NO Not detected at the reputing Emit (or MDL or EDL if shown) POL Practical Quantitation Umit QC QuaGly Controi RER Relative enxir ratio RL Reporting Limit or Requested Limit (Radiochemlstry) RPD Reielive Percent Difference, a measure of the relative difference between two points TEF ToMdty Equivalmt Factor (Dioxin) TEQ Toxicity Equivalent Chiotfent (Dioxin) o

TestAmerica Cedar Falls

Page 7 of 12 12/3/2013

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014

Certification Summary Client Environmental Quality Mgt, Inc. TestAmerica Job ID: 310-20598-1 Project/Site: SVDA Site 32 SDG: 030240.0018.02 Laboratory: TestAmerica Cedar Falls All certificBtions held by this laboratory are listed. Not ^1 certifications are applicable to this report.

Authority Program EPA Region CertificadonD expiration Dale AHA HLAP 101044 11-0M4 •Inois NELAP 200024 11-29-14 Iowa State Program 7 12-01-13* Kansas NELAP &10341 01-31.14 Minnesota NELAP 019-999.319 12-31-13* North Dakota Sate Program R-186 09-29.13' Oregon NELAP IA100001 09-29-14 Wfoconsbi State Program 999917270 09-31.14

o

' Explrtd cwtle*«on Is cuirsnlly pwidkig r»n«t«l and is eonsidaiad vaid. TestAmerica Cedar Falls

Page 8 of 12 12/3/2013

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Ine. March 2014 c Method Summary Client Environmental Quality Mgt, Inc. TestAmerica Job ID: 310-20598-1 Project/Site: SVDA Site 32 SDG: 030240.0018.02

Method Deecrtplion Lehoritoiy 601OC Metals (ICP) SW846 TALCF 7470A Mercury (CVAA) SWB46 TALCF

Protocol RefererKes: SW646 ' -Test Methods For Evalualing Sold Waste, PhysicaK:henijcal Melhod«-, Third Edtfon, November 1986 And Its Updates.

Laboratory References: TAL CF = TestAmerica Cedar Fals, 704 Enterprise Drive. Ceder Falls, lA 50613, TEL (319)277-2401

TestAmerica Cedar Falls

Page 9 of 12 12/3/2013

March 2014 Site 32-National Guard Pistol Range Final Completion Report Eg Environmental Quality Management, Inc. March 2014

TestArnerica festAmenca Sample Receii o • tib VL.VJbM IWI NVIIiMMbU"'"' Cedar Falls Facility TM Efltorafte i>iv« • Caoor Flic, lA SflCIn 310-20S98 Chain of Custody.

Client: Project:

City: State:

Date:! F c^Cn ^33sceiver's Inltals: C h-4 _Time (Delivered): 0

Temperature Record: Thermometer: Courier:

Cooler ID#(i(Apoiicabi8) ^]|R"E"-111531506 ^UPS TA Courier PC- niRTronl"-61854108 I IFedEx TA Field Services Uncorrected lemp: ^IR 'G*- 130195822 FedEx Ground Client

^IR'H"-130195853 US Postal Service Other

Corrected3Ctea Temp:I Other: ^Spee-Dee &c Exceptions Noted:

Temperature blank Sam,ple(s) not received in cooler

Tempera:u-e out of compliance Sample(s) received same day of sampling

Coolant Record: IEvidence of chilling process

Received on ice Temp blank <0°C, samples NOT FROZEN

^Wet ice Temp blank <0'C, samples FROZEN

Blue ice Temperature not taken: cmacaienasoni

Dry ice

Other:

NONE iNon-Conforma.hce Report Started Custody Seals:

Cooler Custody Seals Present? Cooler Custody Seals Intact?

No No N/A Sample Custody Seals Present? Sample Custody Seais intact2 Yes Ives No N/A

Document No.: C:h.G-WI-002 Revision: 20 Date: 7/31/2013

Page 10 of 12 12/3/2013

March 2014 B m Codaf Fnlla Division Phone 319-277-2401 or 800-750-2401 lb ^Ist us In using the pn^ enalytical methods,

a> Matrix Preservation & # of Coria^ers Arralyze For; | TAT /QC Dellverabiss a>B _^tan(lard / None 3 ^Rush (surcharges may apply) 1 Ifi / Level 2 / iSMonoc; 3 Data NeedstJ: T/fT Q m / Levels O u / Level 4 0 i Pax ResutU; Y N , 1 Other;

Date Sampled / REMARKS SAMPLE 10 Time Sempled •p L o iField Filtered z a t < y 1 mw 1 { N) i

1 J

1 Sfl o U) , *' to Special InsUuctione: \ <. LABORATOjRT COMMENTS: I ! k 3 o" 5 3 S p, Relinquished Received Byrq r^tuy '•'ju JIM Time; mm m n p Relinquished By;T^ .. ar Time: Received By: C- f "€ fV' Dali/jfe-^i' 0 c / 1 g Rellnqulfihed By: Oule: Received By: Date; Time: T3 CI. Time: 2 a s 2 01 o" ^ S 3 £- I ^ 70 KJ CJ 03 O O ^ 3 •T- 2 CfO •U ^ CD Site 32-National Guard Pistol Range Final Completion Report EO Environmental Quality Management, Inc. March 2014

Login Sample Receipt Checklist

Client; Environmental OualSy Mgt., Inc. Job Number: 310-20598-1 SDG Number: 030240.0018.02 f

Login Numbef: 20598 Ust Source: TestAmerica Cedar Falls Ust Number; 1 Creator Wflson, Ctwryt L

Question Answer Radioactivity wasnl checked or is background as measured by a survey N/A meter. The cooiers custody seal, if present, is intact. True Sample custody seals, if present, are intact. N/A The coder or samples do not appear to have been compromised or True tampered with. Samples were received on ice. True Cooler Temperature is acceptable. True Cooler Temperature is recorded. True COC is present. True COC is filed out in ink and legible. True COC is filed out with all pertinent informatton. True Is the Field Sampler's name present on COC? Tnre There are no discrepancies between the containers received and the COC. True Samples are received within Hddng Time. Tnre Sample containers have legible labels. Tnre Containers are not broken or leaking. True Sample cdlectiondateAimes are provided. Tnre Appropriate sample containers are used. True Sample bottles are completely filled. True Sample Preservation Verified. True There is sufficient vd. for ali requested analyses, inci. any requested True MS/MSDs Containers requiring zeroheadspace have no headspace or bubble is Tme <6mm (1/4-). Multiphasic samples are nd present. True Samples do nd require spilling or compositing. Tnie Residual Chlorine Checked. N/A

TestAmerica Cedar Fails Page 12 Of 12 12A3/2013

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014

wm mmtmtom'm Nen

c. Typical Color(s): BrawL d Strong Odor? • Yes No Describe: e Physical State at 70°F: Solid • Liquid • Powder • Semi-Solid or Sludge • Other. f. Layers? Sf Single layer QMulti-layer CKA g. Water Reacfive? • Yea Si No If Yes. Describe: h. Free Liquid Range (%): to si NA(solld) i. pH Range: to ^ NAfsoUd) j. Uquid Flash Point: • < 140°F • I40°- 199T • > ZOtPF Gf NA(soUd) k. Flammable Solid: • Yes Si No

Constituents CTotal CompontionMust be > 100*/^) Lower Range tlnilofMuiiue t!ppm!t»HBe Unit ol Measure 1. Soil 95 % 99 % 2. Wood Debris 1 % 5 % 3. Veoetation 1 % 5 % 4. Spent bullets, sluas and shot Trace Trace S. 6.

2. ESTIMATED OUANTITY OF WASTE AND SHIPPING INFORMATION a. One Time Everu • Base • Repeat Event b. Estimated Annual Quantitv: 50-60 Tbns • CubicYards • Drums • Gallons • Other (specify): c. Shipping Frequency: 3-4 tandem truck loads Units per • Month •(Quarter QYear iSi One Time • Other d. Is this a U.S. Department of Transportation (USDOT) Hazardous Material? (If yes, answer e.) • Yes 1^ No e. USDOT Shipping Description (if applicable): _NA 3. SAFETY REQUIREMENTS (Handling. PPE. etc.l: Standafd Landfill PPE

®2010 Waste Management, Inc. Page 1 of 2 May 2010 w-

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014

r'a Nwhaawvdofis Wast« PveOl* Sheet

^ D. Regnlatoiry Itatue (Wea»e chech app»opriat» »e»pon»«»)

1. Waste Identification; a. Does the waste meet the definition of a USCPA listed or characteristic hazardous waste as defined by 40 CFR Fan 2617 • Yes 9 No I. If yes, please complete a hazardous waste profile. b. Does the waste meet the definition of a state hazardous waste other than identified in D. 1 .a? • Yes Sf No 1. If yes, please complete a hazardous waste profile. 2. Is this waste included inone or more of categories below (Check all that apply)? If yes, atuch supporting documentatioiu • Yes No • Delisted Hazardous Waste • Excluded Wastes Under 40CFR 261.4 • Treated Hazardous Waste Debris • Treated Characteristic Hazardous Waste 3. Is the waste froma Federal (40 era 300, Appendix B) or state mandated tdean-up? If yes, see instructionB. • Yes ^No 4. Does the waste represented by this waste profile sheet contain radioactive material? • Yes SINO a. If yes, is disposal regulated by the Nuclear Regulatory Commission? • Yes QNO b. If yes, is disposal regulated by a State Agency for radioactive waste/NORM? a Yes QNO 5. Does the waste represented by this waste profile sheet contain Polychlorinated Biphenyls (PCBs)? • Yes dNt (If yes, list in Chemical CongxDsition - C. 1 J) a. If yes, are the PCBs regulated by 40 CFR 761? • Yes QNO b. If yes, is it remediation waste from a project being performed under the Self-bnplementing option provided in 40CFR781.61(a)? • Yes QNO c. If yes, were the PCBs imported into the US? • Yes QNO 6. Does the waste contain untreated, regulated medical or infectious waste? • Yes Sl No 7. Does the waste contain asbestos? • Yes Si No a. If Yes, a Friable • Non lYiable 8. Is this profile for remediation waste from a facility that is a major source of Hazardous Air Pollutants (Site Remediation NESHAP, 40 era 63 subpart GISGGG)? • Yes ^No a. Ifyes, does the waste contain <600 ppmwVOHAPs at the point of determination? • Yes ONO

C. Oemesratoe CesWcaMom QPIe—e ireaJ and ceatMy by «ig—4a»e below) By signing this Generator's Waste Profile Sheet, 1 hereby certify that all:

1. Information submitted in this profile and all attached documents contain true and accurate descriptions of the waste material: 2. Relevant information within the possession of the Generator regarding known or suspected hazards pertaining to this waste has been disclosed to WM/the Contractor; 3. Analytical data attached pertaining to the profiled waste was derived from testing a representative sample in accordance with 40 era 261.20(c) or equivalent rules; and 4. Changes that occur in the character of the waste (i.e. changes in the process or new analytical) will be identified by the Generator and disclosed to WM (and the Contractor if applicable) prior to providing the waste to WM (and the contractor if applicable). 5. Check all that apply. id a. Attached analytical pertains to the waste. Identify laboratory & sample ID #'s and parameters tested: Test America. Sample ID 310-20598-1. TCIP Metals # Pages; • b. Only the analysis identified on the attachment pertain to the waste (identify by laboratory & sample ID #'s and parameters tested). Attachment#; • c. Additional information necessary to characterize the profiled waste has been attached (other then analytical, such as MSDS). Indicate the number of attached pages: • d. 1 am an agent signing on behalf of the Generator, and the delegation of authority to me from the Generator for this signature is available upon request.

Certification Signature::e:t 7.B. Company Name: Name (Print): I Date:

©2010 Wa«te Management, Inc. Page 2 of 2 May sow

March 2014 Site 32-National Guard Pistol Range Final Completion Report Environmental Quality Management, Inc. March 2014

Profile Addendum: State of niiaois yum GENERATOR'S NON'SPECIAI. WASTE CERTIITCATION

r.adJnio««n»i—f «» naatloa

Profile Number:.

Generators Name: u s. Annv. Former Savanna Arniv Depot Activity

Generators SITE Address: Site 32.1B935 B Street. Savanna. IL 61074 (Tbe location where the waste is generated)

Waste Name: Lead Contaminated Soil

The Illinois Environmental Protection Act allows a Generator to certify that their pollution control waste or industrial process waste, is not an Illinois Special Waste (Section 3.45). By completing the following questionnaire, you may certity that the waste stream represented by the Waste Management Profile referenced above is not an Illinois Special Waste as defined in the Act.

Is the waste referenced above any of the following: 1. A Potentially Infectious Medical Waste (PIMW)? • Yes 13 No 2. A Hazardous Waste as defined in 40 CFR 261 or in 35 lAC 722.111? • Yes 0 No 3. A Liquid Waste (fails the paint filter test as defined in 35 lAC 811.107)? • Yes 0 No 4. A regulated PCB waste as defined in 40 CFR 761? • Yes 0 No 5. A NESHAP regulated asbestos waste other than waste from renovation or demolition? • Yes 0 No 6. A waste resulting from the shredding recyclable metals (auto Huff)? • Yes 0 No 7. A delisted Hazardous Waste or Treated Characteristic Hazardous Waste, subject to LDR requirements under 35 lAC 728.107? • Yes 0 No In determining that this waste is not a liquid, I have used knowledge of the processes generating the waste and the attached supporting documentation: • MSDS • Analytical 0 Other (explain below): Generator knowledQe - waste maletial is soil.

In determining that this waste is not RCRA hazardous, I have used knowledge of the processes generating the waste and the attached supporting documentation: • MSDS 0 Analytical 0 Other (explain below): Gyigralprkniywlyjqe

8. Is the waste represented by this profile sheet subject to the Illinois Solid Waste Management Act fee? 0 Yes • No

By signing below, I certify my waste is NOT an Illinois Special Waste, and that I understand that a person who knowingly and falsely certifies that a waste is not special waste is subject to the penalties set forth in subdivision (6) of subsection (h) of section 44 of the Illinois Environmental Protection Act.

tv/i

Name; (Print). Title: vsi/jce

Signature:e; M r Date:,

Marrh 9ni4 Site 32-National Guard Pistol Range Final Completion Report EQ Environmental Quality Management, Inc. March 2014

INDUSTRIAL WASTE & DISPOSAL SERVICES fit • ^ Exhibit A wWMn MAMMIEMEMT AGREEMENT

CUSTOMER WF0RMM10N GaetATCAMFORMATUN yail«rt*o«.CaMa»flnfannrt PROFLENUHBai: 607979IL EQM US Amiy, Fornier Savanna Aimy Depot DISPOSAL FAOLHY: Prairie Hill RDF tSOOCaillion 18935BSt FROFLEEXPRATIONDATE: 12/05/2014 Cinannati.OH 45240- Savanna,! 61074 PC NUMBER: Contact Name: Craig Hoby Contact PiMne: - Service Material/Ticket Description /Anticipated Volume Rate/UOM/Minimum Infonnation Disposal Lead Contaminated Soil 60 Ten »S.88n'on(Mn: 2.0 Tons)

ProiaeFee S35.(XVEadi Tax states Local Fees/Taxes Fuel *See Note Below cnVnOOiiNinlal, T - - . 1 .i II 1 $14.0C/load S14.0a!oad RCR Regulatory Cost Recovery Chaige 62.m

Digout(ln]zanload): $25.C0/1oad Washout Fee: $75.00Toad CeiticalaotBiirial/DBskiiclon: SSOJWsadiend R^eclionFee(relaaded): fSOOQItoai Wests Ban Itena: SSO.OOtoad SpedatHandfog/Buiial: IBDbyrap-minlnun $200.0(Moad Rejedlcn Fee (WM reload formovement on site): Appiancss/Wlits Goods Rejedion; SSO.OQArad $5Q/load

Quantity; Size: Quantity: Size: - Acceptance of vosta Is contingsnt upon the compiefion, submittal and approval of ipacial waata proffia sheet required anMytical, industrial Waste & Disposal Sarvkes Agraemant (iSA), and Exhibit A. All loads must be manifested. Confirmation wlll be sent to ArMHkmal customer upon approval to ship Into designated fadfiiy. InformationfSpecial - Prices quoted herein are valid for 60 days ftom Friday, Dacenfoer 06,2013 unless Waata Management is hired for this project prior Handing: to the explratiDnof this 60 day period InvAich caaa pricing remaina valid in accordanca with thetenne of the Service Agreement - The hiel surcharue percentaoe can fluctuate on a vwsklv basis: www.wm.com orovidsa the currant Fuel Surchatoe and DOE average. The actual percentage rate applied to the total project invoice will bedetermfoed the weeic that the hvoica la generated. - It Waste Management (or a Waste Managamant contracted hauler) Is NOT provldng the transportation services, you must ensure that the trinspoiler fo licsnsed afo approved to haul the Sp^l Wests or Ha^ous Waste. - Please seeprotlla appraval fbmi for special handUng hstructiona.

THE WORK CONTEMPLATED BY THIS EXHIBIT A IS TO BE DONE M ACCORDANCE WITH THE TERMS AND CONDITIONS OF THE INDUSTRIAL SERVICES AGREEMENT OR OTHER CONTRACTUAL AGREEMENT BETWEEN THE PARTIES DATED: ±L

COMPANY Waste Management of Mnois, Inc. CUSTOMER By: Signature: Nane; Kaila Scarce Date Name: rae Technical Service Representative Title: (800)WMDispo$al or (800) 963-4776 FAX: 866-600-2591

eWaittMana L Inc. (rav. 20003) ExhlM A - INDUSTRIAL WASTE S DISPOSAL AGREEMENT

March 2014 Site 32-National Guard Pistol Range Final Completion Report EQ Environmental Quality Management, Inc. March 2014

WASn MAHAGbMltrm Industrial Waste Tracking Receipt (Non-Special) Profile Number: 607979IL Expiration Date: 12/05/2014 ALL LOADS MUST BE SCHFDITT FD 24 HOURS IN ADVANCE

2 Copies needed with each driver on their 1®* load of each day

Si ition A Gent'i alor Inl'ormation

'Generator Name: Tedinlcal Contact and Phone: US Amy, Former Savanna Amy Depot ToddKnuth8l5-273-8905

Street Address: 18935 B St; Savanna, IL61074

County: Carroll On Site Contact: Craig Hoby - -

Waste Name: Lead Contaminated Soil

Volume/Number of Drums:

Special Conditions:

NO Generator Signature Reoulred l it WSI'OKn R IMORMATION

Transporter: ,p gwaua. txc.

Driver Signlture:

Truck Number: Date:

1 1 IStction C DISPOSAf. SI ! i; i\rORMA1 ION

Site Name.-Prairie Hill RDF lEPA ED Number: 1950350014

Authorized Signature Date(MM«)D/YY)

Load 1. Load 2 Load 3 Load 4 Load 5.

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014 IIIIAYAA, '

March 2014 Site 32-National Guard Pistol Range Final Completion Report Eg Environmental Quality Management, Inc. March 2014

wtMArrt MANAGtMEMT Industrial Waste Tracking Receipt (Non-Special) Profile Number: 607979IL Expiration Date: 12/05/2014 ALL LOADS MUST BE SCHEDULED 24 HOURS IN ADVANCE 2 Copies needed with each driver on their l*' load of each day

Suction A (icncrntor [nioniiiilioii

deiierator Name: Technictd Contact and Phone: US Army, Former Savanna Army Depot ToddKnuth815-273-8905

Street Address: 18935 B St; Savanna, E,61074 County: Carroll

On Site Contact: Craig Hoby - -

Waste Name: Lead Contaminated Soil

Volume/Number of Dnnns: Special Conditims:

NO G^eyator Sigpapiire Rypiiyyd

Sccliiin 11 I P \NSPOK I l.U IMORM M ION

Transporter: fetetiS eg PeaUaft n>c. Driver Si Truck Number: ^3 Date:_i$iJ3L)3_

1 , 1 ISccliun t' DlSl'ttS \l. sn 1 IMOKM \ riUN 1 Site Name-^Pram^^^^DF lEPA ID Number: 1950350014 ^ / A^-/s—/3 Authorized Signature Date (MM/DD/YY)

Loadl Load2 IZ Load 3 Load 4 Loads. '71.*.

March 2014 Site 32-National Guard Pistol Range Final Completion Report m Environmental Quality Management, Inc. March 2014

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Industrial Waste Tracking Receipt (Non-Special) Profile Number:

ALL LOADS MUST BE SCHEDULED 24 HOURS IN ADVANCE

2 Copies needed with each driver on their 1'^ load of each day

Generator Name: Technical Contact and Phone: US Array, Former Savanna Army Depot ToddKnuth 815-273-8905

Street Address: 18935 B St; Savanna, IL 61074

County: Carroll

On Site Contact: Craig Hoby - -

Waste Name: Lead Contaminated Soil

Voiome/Numbcr of Drums:

Special Conditions: w- NO Generator Signature Required

I It Wsj'OK 1 I K IN!OKM \ Il()\

Transporten

Driver Signature:

Truck Number:_ Date; J 9 / f i / / J)

I I IM (IKM \ HON

Hill RDF lEPA ED Number:,

Authorized Signature Date (MM/DD/YV)

Loadi Load 2 Load 3 Load 4 Loads

March 2014