Record of Decision Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 Savanna Army Depot Activity Savanna, Illinois
Final
Prepared for:
Louisville District 600 Dr. Martin Luther King, Jr. Place Louisville, Kentucky 40202
Prepared by:
Science Applications International Corporation 8301 Greensboro Drive McLean, Virginia 22102
August 2013
Contract No. DACW62-03-D-0003, Delivery Order No. CY01, SAIC CRN 142044 Contract No. W912QR-08-D-0008, Delivery Order No. 0012, SAIC CRN 180617
Record of Decision
Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 827.20130822.001 Savanna Army Depot Activity Savanna, Illinois
Final
Prepared for:
U.S. Army Corps of Engineers Louisville District Louisville, Kentucky 40202
Prepared by:
Science Applications International Corporation 8301 Greensboro Drive McLean, Virginia 22102
Contract No. DACW62-03-D-0003, Delivery Order No. CY01, SAIC CRN 142044 Contract No. W912QR-08-D-0008, Delivery Order No. 0012, SAIC CRN 180617
August 2013
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Certification 4 CONTRACTOR STATEMENT OF INDEPENDENT TECHNICAL REVIEW
Science Applications International Corporation (SAIC) has completed the Record of Decision for Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 at Savanna Army Depot Activity, Savanna, Illinois. Notice is hereby given that an independent technical review has been conducted that is appropriate to the level of risk and complexity inherent in the project as defined in the SAIC Quality Assurance Plan. During the independent technical review, compliance with established policy principles and procedures, using justified and valid assumptions, was verified. This included review of assumptions, methods, procedures, and materials used in analyses; the appropriateness of data used and the level of data obtained; and assessment of the reasonableness of the results, including consistency with U.S. Army Corps of Engineers (USACE) policy.
August 20, 2013 Marcy Larriva, P.E., PMP Date Project Manager
August 20, 2013 Joseph E. Peters Date QA Manager
August 20, 2013 Jed Thomas, P.E. Date Independent Technical Review Team Leader
Significant concerns and explanation of the resolutions are documented within the project file. As noted above, all concerns resulting from independent technical review of the project have been considered.
August 20, 2013 Lisa Jones-Bateman, REM, PMP Date Vice President
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TABLE OF CONTENTS Page 1. DECLARATION ...... 1-1 1.1 INSTALLATION LOCATION AND SITE NAMES ...... 1-1 1.2 STATEMENT OF BASIS AND PURPOSE ...... 1-1 1.3 DESCRIPTION OF SELECTED REMEDY AND ASSESSMENT OF THE SITES ...... 1-3 1.4 STATUTORY DETERMINATIONS ...... 1-3 1.5 ROD DATA CERTIFICATION CHECKLIST ...... 1-4 1.6 AUTHORIZING SIGNATURES ...... 1-5 2. DECISION SUMMARY ...... 2-1 2.1 INSTALLATION HISTORY, SITE NAMES, AND LOCATIONS ...... 2-1 2.2 SITE HISTORY AND REGULATORY ACTIVITY ...... 2-1 2.3 COMMUNITY PARTICIPATION ...... 2-9 2.4 ENVIRONMENTAL SETTING ...... 2-9 2.5 SCOPE AND ROLE OF RESPONSE ACTION ...... 2-9 2.6 SITE DESCRIPTIONS ...... 2-10 2.6.1 Site 5 (Liquid Propellant Burn Area) ...... 2-10 2.6.2 Site 24 (CF Plant Melt and Pour Facility) ...... 2-11 2.6.3 Site 37PS (Pole Storage Area) ...... 2-13 2.6.4 Site 69 (Contaminated Waste Processor – Building 2215) ...... 2-14 2.6.5 Site 76CS (Former Coal Storage Area) ...... 2-15 2.6.6 Site 76OD (Open Drum Storage Area) ...... 2-17 2.6.7 Site 126 (CN Plant Boiler Building USTs, Building 502) ...... 2-18 2.6.8 Site 155 (CF Plant Drilling and Boostering Building – Building 729) ...... 2-19 2.6.9 Site 184 (CL Plant Compressor Building – Building 640) ...... 2-21 2.6.10 Site 186 (CF Plant Generator Building – Building 707) ...... 2-21 2.7 HISTORICAL AND POTENTIAL FUTURE LAND USES ...... 2-23 2.8 SUMMARY OF SITE RISKS ...... 2-23 2.8.1 Screening Evaluation ...... 2-23 2.8.2 Human Health Risk Assessment ...... 2-24 2.8.3 Ecological Risk Assessment ...... 2-26 2.9 REMEDIAL ACTION OBJECTIVES ...... 2-27 2.10 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS ANALYSIS...... 2-27 2.11 DESCRIPTION OF ALTERNATIVES FOR SITES 37PS, 76CS, AND 76OD ...... 2-29 2.11.1 Comparative Analysis of Alternatives ...... 2-30 2.11.1.1 Overall Protection of Human Health and the Environment ...... 2-30 2.11.1.2 Compliance with Applicable or Relevant and Appropriate Requirements ...... 2-30 2.11.1.3 Long-Term Effectiveness and Permanence ...... 2-32 2.11.1.4 Reduction of Toxicity, Mobility, or Volume Through Treatment ...... 2-32 2.11.1.5 Short-Term Effectiveness ...... 2-32 2.11.1.6 Implementability ...... 2-32 2.11.1.7 Cost ...... 2-33 2.11.1.8 Regulatory Acceptance ...... 2-33 2.11.1.9 Community Acceptance ...... 2-33 2.11.2 Principal Threat Waste ...... 2-33 2.11.3 Selected Remedy ...... 2-34 2.12 DESCRIPTION OF ALTERNATIVES FOR SITE 126 ...... 2-34 2.12.1 Comparative Analysis of Alternatives ...... 2-35
Savanna Army Depot, Final ROD v August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
TABLE OF CONTENTS (Continued) Page 2.12.1.1 Overall Protection of Human Health and the Environment ...... 2-35 2.12.1.2 Compliance with Applicable or Relevant and Appropriate Requirements ...... 2-37 2.12.1.3 Long-Term Effectiveness and Permanence ...... 2-37 2.12.1.4 Reduction of Toxicity, Mobility, or Volume Through Treatment ...... 2-37 2.12.1.5 Short-Term Effectiveness ...... 2-38 2.12.1.6 Implementability ...... 2-38 2.12.1.7 Cost ...... 2-38 2.12.1.8 Regulatory Acceptance ...... 2-38 2.12.1.9 Community Acceptance ...... 2-39 2.12.2 Principal Threat Waste ...... 2-39 2.12.3 Selected Remedy ...... 2-39 2.13 STATUTORY DETERMINATIONS ...... 2-40 2.14 DOCUMENTATION OF SIGNFICANT CHANGES ...... 2-40 3. RESPONSIVENESS SUMMARY ...... 3-1 3.1 BACKGROUND ON COMMUNITY INVOLVEMENT ...... 3-1 3.2 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD ...... 3-1 3.2.1 Public Meeting Comments and Resolution ...... 3-1 3.2.2 Public Meeting Comments and Follow-up Resolution ...... 3-2 3.2.3 Written Comments ...... 3-4 4. REFERENCES ...... 4-1
LIST OF APPENDICES
Appendix A. Human Health Risk Assessment Summary Appendix B. Ecological Risk Assessment Summary Appendix C. Public Meeting Sign-in Sheet, Public Meeting Transcript, and Written Public Comments
Savanna Army Depot, Final ROD vi August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
LIST OF FIGURES Page Figure 1-1. Savanna Army Depot Activity Installation Location ...... 1-2 Figure 2-1. Record of Decision Site Locations ...... 2-8 Figure 2-2. Sites 37PS, 76CS, and 76OD Proposed Soil Excavation Limits ...... 2-31 Figure 2-3. Site 126 Proposed Excavation Limits ...... 2-36
LIST OF TABLES Page Table 1-1. Data Certification Checklist ...... 1-4 Table 2-1. Key Information for Each ROD Site ...... 2-2 Table 2-2. Potential Federal and State Action-specific ARARs ...... 2-28 Table 2-3. Sites 37PS, 76CS, and 76OD Comparative Summary of Costs and Remediation Timeframe ...... 2-33 Table 2-4. Sites 37PS, 76CS, and 76OD Summary Cost Estimate for Alternative 4: Excavation and Offsite Disposal for Unrestricted Use ...... 2-34 Table 2-5. Site 126 Comparative Summary of Costs and Remediation Timeframe ...... 2-38 Table 2-6. Site 126 Summary Cost Estimate for Alternative 4: Excavation and Offsite Disposal for Unrestricted Use ...... 2-39 Table 2-7. Cleanup Goals ...... 2-40
Savanna Army Depot, Final ROD vii August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
LIST OF ACRONYMS AND ABBREVIATIONS 1,3,5-TNB 1,3,5-Trinitrobenzene 2,4-DNT 2,4-Dinitrotoluene 2,6-DNT 2,6-Dinitrotoluene 2-A-4,6-DNT 2-Amino-4,6-Dinitrotoluene 4-A-2,6-DNT 4-Amino-2,6-Dinitrotoluene APCS Air Pollution Control System APE Ammunition Peculiar Equipment AR Army Regulation ARAR Applicable or Relevant and Appropriate Requirement AUF Area Use Factor B2EHP Bis(2-Ethylhexyl) Phthalate BCT BRAC Cleanup Team BLS Below Land Surface BMP Best Management Practice BNA Base/Neutral and Acid Extractable BRAC Base Realignment and Closure BTEX Benzene, Toluene, Ethylbenzene, and Xylenes CAPE Cape Environmental Management, Inc. CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CERCLIS Comprehensive Environmental Responses, Compensation, and Liability Information System CFR Code of Federal Regulations COC Chemical of Concern COPC Chemical of Potential Concern cPAH Carcinogenic Polynuclear Aromatic Hydrocarbon CWP Contaminated Waste Processor DA Department of the Army DERA Defense Environmental Restoration Account DNBP di-Ni-Butyl Phthalate DOD U.S. Department of Defense EBS Environmental Baseline Survey ecoCOPC Ecological Chemical of Potential Concern EE/CA Engineering Evaluation/Cost Analysis ERP Environmental Restoration Program ESE Environmental Science and Engineering ESV Ecological Screening Value EWI Explosive Waste Incinerator FFA Federal Facility Agreement FFS Focused Feasibility Study FS Feasibility Study GQS Groundwater Quality Standard HASP Health and Safety Plan HI Hazard Index HMX Cyclo-1,3,5,7-tetramethylene-2,4,6,8-tetranitramine HQ Hazard Quotient I.D. Identification IAC Illinois Administrative Code IDNR Illinois Department of Natural Resources IEPA Illinois Environmental Protection Agency IR Information Repository IRP Installation Restoration Program
Savanna Army Depot, Final ROD viii August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
LIST OF ACRONYMS AND ABBREVIATIONS (Continued)
ISPCS Illinois State Plane Coordinate System LRA Local Redevelopment Authority LUC Land Use Control MCL Maximum Contaminant Level NCP National Oil and Hazardous Substances Pollution Contingency Plan NOI Notice of Intent NOT Notice of Termination NPDES National Pollutant Discharge Elimination System NPL National Priorities List O&M Operation and Maintenance P.E. Professional Engineer PAH Polynuclear Aromatic Hydrocarbon PBT Persistent, Bioaccumulative, and Toxic PCB Polychlorinated Biphenyl PCP Pentachlorophenol PL Public Law PMP Project Management Professional PRG Preliminary Remediation Goal RAB Restoration Advisory Board RACR Removal Action Construction Report RAO Remedial Action Objective RCRA Resource Conservation and Recovery Act RDX Cyclo-1,3,5-Trimethylene-2,4,5-Trinitramine REM Registered Environmental Manager RFNA Red Fuming Nitric Acid RI Remedial Investigation RIP Receiving, Inspection, and Painting ROD Record of Decision RSE Removal Site Evaluation RSL Regional Screening Level SAIC Science Applications International Corporation SARA Superfund Amendments and Reauthorization Act SERA Screening-level Ecological Risk Assessment SVDA Savanna Depot Activity SVOC Semivolatile Organic Compound SWPP Stormwater Pollution Prevention TACO Tiered Approach to Corrective Action Objectives TBC To-Be-Considered TCE Trichloroethene TCLP Toxicity Characteristic Leaching Procedure TNT 2,4,6-Trinitrotoluene TRV Toxicity Reference Value UDMH Unsymmetrical Dimethyhydrazine UECA Uniform Environmental Covenant Act USEPA U.S. Environmental Protection Agency USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey UST Underground Storage Tank VOC Volatile Organic Compound
Savanna Army Depot, Final ROD ix August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
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1. DECLARATION This Record of Decision (ROD) documents the environmental resolution for Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 at Savanna Army Depot Activity (SVDA), Savanna, Illinois. The ROD considers public comment received on the Proposed Plan dated November 2012 (SAIC 2012) and is a legal, technical, and public document that describes the selected remedies for the sites. Section 1 presents key information regarding the sites presented in this ROD. Section 2 summarizes site information and investigation conclusions and explains how the selected remedies will fulfill the statutory and regulatory requirements. Section 3 summarizes information about the views of the public and regulatory agencies regarding the site recommendations and any general concerns about the sites. 1.1 INSTALLATION LOCATION AND SITE NAMES SVDA was a 13,062-acre Army installation located on the eastern bank of the Mississippi River in Carroll and Jo Daviess Counties approximately 7 miles north of the city of Savanna, Illinois and approximately 150 miles west of Chicago, Illinois (Figure 1-1). The CERCLA Information System (CERCLIS) identification (I.D.) number for SVDA is IL3210020803. Sites addressed in this ROD include the following: • Liquid Propellant Burn Area (Site 5) • CF Plant Melt and Pour Facility (Site 24) • Pole Storage Area (Site 37PS) • Contaminated Waste Processor (CWP) (Building 2215) (Site 69) • Former Coal Storage Area (Site 76CS) • Open Drum Storage Area (Site 76OD) • CN Plant Boiler Building USTs (underground storage tanks) (Building 502) (Site 126) • CF Plant Drilling and Boostering Building (Building 729) (Site 155) • CL Plant Compressor Building (Building 640) (Site 184) • CF Plant Generator Building (Building 707) (Site 186). 1.2 STATEMENT OF BASIS AND PURPOSE This ROD presents the resolution for remedial action at four sites (Sites 37PS, 76CS, 76OD, and 126) and no action at six sites (Sites 5, 24, 69, 155, 184, and 186) at SVDA as selected by the U.S. Environmental Protection Agency (USEPA) in consultation with the Army and the Illinois Environmental Protection Agency (IEPA) and in accordance with CERCLA, as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986; the Resource Conservation and Recovery Act (RCRA); and to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The remedies selected for the 10 sites are the result of the evaluation of alternatives conducted in a Feasibility Study (FS) (SAIC 2010a), Focused Feasibility Study (FFS) (SAIC 2010b), Removal Site Evaluation (RSE), and Engineering Evaluation/Cost Analysis (EE/CA) (URS 2008a and 2008b), and the preferred remedy documented in a Proposed Plan (SAIC 2012). The Army and IEPA concur with the selected remedy. The remedy solution is consistent with RCRA-CERCLA integration, as discussed in Sections I, III, and XIII of the Federal Facility Agreement (FFA). USEPA has determined that remedial action is required at four sites (Sites 37PS, 76CS, 76OD, and 126), and no action is necessary at six sites (Sites 5, 24, 69, 155, 184, and 186) to protect public health, welfare, or the environment. This decision is supported based on the Administrative Record for the 10 sites.
Savanna Army Depot, Final ROD 1-1 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
02.5 5 10 15 20 Miles
SAVANNA ARMY DEPOT ACTIVITY INSTALLATION LOCATION SAVANNA ARMY DEPOT ACTIVITY SAVANNA, ILLINOIS PROJECT: \GIS_DATA\SVAD\Projects\Sites_24_76CS_99_126\ 10 Sites ROD\Figure 1-1 Installation Location.mxd FIGURE: 1-1 DATE: 1/24/2013 Savanna Army Depot, Final ROD 1-2 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
1.3 DESCRIPTION OF SELECTED REMEDY AND ASSESSMENT OF THE SITES Field investigations, laboratory analyses, review of current and future land use, and human health and ecological risk assessments were conducted at each of the 10 sites presented in this ROD. Based on site-specific ecological risk assessments, the ecological risks were determined to be acceptable at all 10 sites. The site-specific human health risk assessments evaluated the potential for adverse health effects for groups of people likely to be present under the planned industrial/commercial use of Sites 24, 37PS, 76CS, 76OD, 126, 155, 184, and 186 (i.e., industrial and construction workers). In addition, the human health risk assessments evaluated the potential for adverse health effects for groups of people present under recreational use of Sites 5 and 69 (i.e., recreational receptors and construction and industrial workers). Finally, the human health risk assessments evaluated the potential for adverse health effects for groups of people present under the hypothetical residential use of the 10 sites (i.e., residents). The human health risk assessment conducted at Sites 37PS, 76CS, and 76OD indicated concentrations of volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs), and metals in soil exceeded screening levels and migration to groundwater screening levels. At Site 126, the human health risk assessment identified polynuclear aromatic hydrocarbons (PAHs) in soil exceeding screening levels. Based on the human health risk assessments, human health risks are unacceptable at four sites (Sites 37PS, 76CS, 76OD, and 126). The selected remedy for these sites is removal of impacted soil and disposal at an offsite facility, resulting in unrestricted land use. Six sites (Sites 5, 24, 69, 155, 184, and 186) were identified in the human health risk assessments as having human health risks acceptable for all receptors and land uses and the preferred remedy is no action. 1.4 STATUTORY DETERMINATIONS SVDA was placed on the National Priorities List (NPL) in 1989. As a result of the NPL listing, the Army entered a three-party FFA with USEPA Region 5 and IEPA in September 1989 (DA 1989). Environmental restoration activities under the FFA (Sections I, III, and XIII) must comply with CERCLA and RCRA requirements and procedures in accordance with the FFA. In 1995, SVDA was selected for closure under the Base Closure and Realignment Act of 1990 (Base Closure Act), as amended, and SVDA officially closed in March 2000. Currently, the only onsite Army activities are associated with the assessment and remediation of site-related contamination as required under CERCLA and the Base Realignment and Closure (BRAC) Act and the preparation for transferring ownership of land parcels to other governmental entities or the Local Redevelopment Authority (LRA). The selected remedy (i.e., excavation and offsite disposal for four sites and no action for six sites) is based on CERCLA- mandated site investigations, laboratory analyses, review of current and future conditions and land reuse, removal activities, and assessment of the human health and ecological risks. Investigations and assessments at these sites are complete. Based on the Remedial Investigation (RI) and assessment findings, USEPA and the Army determined that four sites (Sites 37PS, 76CS, 76OD, and 126) require remedial actions (i.e., excavation and offsite disposal) to address the soil chemicals of concern (COCs.) This remedy is protective of human health and the environment, complies with Federal and state requirements that are legally applicable or relevant and appropriate to the action, is cost effective, and uses permanent solutions to the maximum extent practicable. Because this remedy will result in unlimited use and unrestricted exposure, a 5-year review will not be required for these four sites. Based on the RI and assessment findings, USEPA and the Army believe that six sites (Sites 5, 24, 69, 155, 184, and 186) may be used without restrictions and that no action is needed to protect human health and the environment. In light of the decision not to select a remedial action, the requirements of CERCLA Section 121, including the provisions of CERCLA Section 121(d)(2) concerning applicable or
Savanna Army Depot, Final ROD 1-3 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
relevant and appropriate requirements (ARARs), are not triggered; that section applies only in those cases where a remedial action is selected. Because this remedy will result in unlimited use and unrestricted exposure, a 5-year review will not be required for these six sites. The selected remedy (i.e., excavation and offsite disposal) at Sites 37PS, 76CS, 76OD, and 126 and no action at Sites 5, 24, 69, 155, 184, and 186 satisfy the statutory requirements of CERCLA. 1.5 ROD DATA CERTIFICATION CHECKLIST A data certification checklist is provided in Table 1-1. The checklist certifies that the ROD contains information pertinent to the remedy selection and identifies the ROD section within the body of this document. Table 1-1. Data Certification Checklist Savanna Army Depot Activity, Savanna, Illinois
Information ROD Section COCs Section 2.6 Section 2.12 Baseline Risk Section 2.8 Cleanup Levels Section 2.12 Source Materials Section 2.11.1.4 Section 2.11.2.4 Current and Future Land Use Section 2.7 Land Use with Remedy Section 2.11.1.5 Section 2.11.2.5 Costs Associated with Remedy Section 2.11.1.5 Section 2.11.2.5 Key Factors for Remedy Selection Section 2.11.1.1 Section 2.11.2.1
Savanna Army Depot, Final ROD 1-4 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
1.6 AUTHORIZING SIGNATURES Soil excavation and offsite disposal is necessary at four sites (Sites 37PS, 76CS, 76OD, and 126) and no action is necessary at six sites (Sites 5, 24, 69, 155, 184, and 186) to ensure protection of human health and the environment. Concur and recommend for immediate implementation:
____ James E. Briggs Date Acting Chief, Reserve and Consolidations Branch Base Realignment and Closure Division
____ Richard C. Karl Date Superfund Division Director U.S. Environmental Protection Agency, Region 5
____ Lisa Bonnett Date Director Illinois Environmental Protection Agency
Savanna Army Depot, Final ROD 1-5 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
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2. DECISION SUMMARY The Army, as the lead agency at SVDA, is responsible for remedial actions at Sites 37PS, 76CS, 76OD, and 126, and no action at Sites 5, 24, 69, 155, 184, and 186 under this ROD. USEPA and IEPA provide regulatory oversight, technical review, and approvals as members of the BRAC Cleanup Team (BCT) for SVDA. The U.S. Department of Defense (DOD) Defense Environmental Restoration Account (DERA) is the source of cleanup-related funding. 2.1 INSTALLATION HISTORY, SITE NAMES, AND LOCATIONS SVDA was a 13,062-acre Installation located on the eastern bank of the Mississippi River. The Installation is located in Carroll and Jo Daviess Counties approximately 7 miles north of the city of Savanna, Illinois and approximately 150 miles west of Chicago, Illinois (see Figure 1-1). The CERCLIS I.D. number for SVDA is IL3210020803. The Army purchased the Installation property in 1917 for the construction of a proof and test facility for artillery guns and ammunition. Operations at the Installation expanded to ordnance storage facilities and loading and renovating shells and bombs. In 1970, a special weapons workshop was added to the Installation. While active, the Installation activities at SVDA included the handling, processing, and storing of munitions, explosives, and industrial chemicals. The storage, maintenance, and industrial functions at SVDA historically have resulted in the generation of hazardous wastes. Facilities and operations at SVDA handled, processed, and managed munitions, explosives, and industrial chemicals since operations began in 1918. Several areas of the Installation were historically used for the demolition and burning of obsolete ordnance. The Installation also provided housing, office space, and industrial plant areas with attendant infrastructure. The 10 sites identified in this ROD consist predominantly of storage and industrial areas. Table 2-1 summarizes key information for each of the 10 sites presented in this ROD, including sampling efforts, chemicals detected, and risk assessment recommendations. The site locations are shown in Figure 2-1. 2.2 SITE HISTORY AND REGULATORY ACTIVITY In February 1995, the Secretary of Defense submitted a recommendation that SVDA be selected for closure. The Base Closure Act, Public Laws (PLs) 100-526 and 101-510 designated SVDA for closure and realignment. The Base Closure Act requires environmental issues at base closure properties to be investigated pursuant to CERCLA. The BRAC Environmental Restoration Program (ERP) began by conducting an Environmental Baseline Survey (EBS) (SAIC 1999). The EBS described the environmental condition of the property and has been used to determine the suitability to lease or transfer excess BRAC property. These efforts resulted in the identification of various areas of concern (sites) throughout the Installation. Subsequently, it became necessary to investigate and clean up, as necessary, environmental contamination prior to the release and reuse of the land. The scope of the investigation activities conducted at sites included preparing project work plans, conducting field investigations, validating and managing analytical data, evaluating the risk to human health and the environment, and documenting the results of the investigations and analyses presented in the RI (Dames & Moore 1994; SAIC 2004, 2007a, 2007b, 2007c, and 2009b), FS/FFS (SAIC 2010a and SAIC 2010b), RSE and Engineering EE/CA (URS 2008a and URS 2008b), Removal Action Construction Report (RACR) (URS 2009), and Proposed Plan (SAIC 2012). Upon completion, these documents were submitted to members of the BCT, the Army, IEPA, and USEPA Region 5 for review and comments. Following a review of this information, the BCT concurred with the Army’s proposed determination that active remediation is required at four sites and no action is required at six sites.
Savanna Army Depot, Final ROD 2-1 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 and 184, 155, 126, 76OD, 76CS, 69, 37PS, 24, 5, Sites ROD Final Depot, Army Savanna Table 2-1. Key Information for Each ROD Site Savanna Army Depot Activity, Savanna, Illinois
Chemical Constituents Preferred Site Media Sampled Detected Human Health Assessment Ecological Assessment Alternative Supporting Documents Site 5 Soil, sediment, VOCs, SVOCs, Risks for industrial workers, Lead and zinc HQs remained above Soil – No Action . Rapid Response and groundwater metals, and anions construction workers, and 1 for plants, shrews, and robins Groundwater – Environmental Surveys (ESE recreational receptors are below the using more realistic exposure No Action 1982) target risk range and the target HI. assumptions. However, the . Preliminary Draft RI Report Residential cancer risks are in the arithmetic mean concentrations of (Dames & Moore 1994) lower half of the target risk range. these metals are below or just . Upper Post RI Report (SAIC slightly above conservative ESVs, The soil risk driver, benzo(a)pyrene, 2009b) is below the IEPA residential suggesting the levels of these . screening value and the groundwater metals are not substantially Sites 5, 69, and 184 FFS risk driver, carbon tetrachloride, is elevated and risks are (SAIC 2010b) below the TACO Tier I groundwater overestimated by the conservative remediation objective, Illinois GQS, nature of the SERA. In addition, and Federal MCL for groundwater. exposure of populations of wildlife Therefore, human health risks are and plants to elevated acceptable at this site. concentrations of the metals would be limited at this site due to the
2 small size (0.3 acres). Therefore, - 2
ecological risks are acceptable at
this site. August August 2013
es & Moore
a (SAIC 2007a) Supporting Documents RI Report the for Plant CF Are ConstructionCompletion forReport Remedial Action Environmental Restoration at the Ammunition Peculiar Equipment Shop DockRear (Site 76AD), Nitric Storage Area (Site 44), and Plant CF (Site (CAPE 25) 2006) Removal Site Evaluation and Engineering Evaluation and Cost Analysis and the CF for CL Areas (Dam 1995) Sites 24, 76CS, 99, and 126 FS (SAIC 2010a) Letter ReportLetter on the Supplemental Groundwater Investigation Plant at the CF Melt and Pour Facility (Site and the24) Building 762 CF Plant Shop Battery (Site 99) (SAIC 2009a)
. . . . .
Preferred Preferred Alternative Soil – No ActionSoil Groundwater – No Action
Site e of ecological receptors to TNB. However, wildlife EcologicalAssessment ly to be limitedly because TACO The soilThe removal action reduced most of the elevated concentrations in of TNT soil. All excavated areas backfilledwere with fill material, further reducing potentialany direct exposur elevated concentrations of TNT in the soil. Prior to the removal action, potentialother source areas were evaluated and explosive concentrations below were ESVs. Ecological soil risksfrom were determined to be acceptable at this site. Predicted concentrations of explosives in surface water potentially discharging from groundwater meet the applicable qualitywater standards under 35 IAC 302 thewith exception of 1,3,5- exposures to elevated TNB are like Equation does R26 not account for degradation and absorption to soils and sediments.
evaluation,
. Key Information ROD Each for . Key -1 2 evaluation of the baseline - Human Health Assessment Table groundwater risks indicated risks overestimated.were In addition, the results of the 2009 supplemental sampling indicated attenuation of groundwater concentrations largely IEPAbelow GQSs and USEPA tapwater RSLs, and human health risks falling likely at the low end of the cancertarget risk range. resultsThe of the soil removal, risk- re and supplemental sampling indicate No Action is soil needed for and groundwater at this site. The soilThe risk assessment conducted prior to the soil removal indicated that remediation necessary. was Confirmatory sampling following soil removal action verified that remaining soil concentrations below were the industrial/commercial cleanup level. sampleOne slightly exceeded residential screening criteria. baselineThe groundwater risk assessment for risks indicated cancer hypothetical residents in the upper half the target of risk range were unacceptable. The re
Savanna Army Depot (Continued) Savann Depot Activity, a, Illinois Army Savanna
Detected Chemical Constituents VOCs, SVOCs, metals, explosives, and anions
Media Sampled Soil, sediment, and groundwater
Site Site 24
Savanna Army Depot, Final ROD 2-3 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
Supporting Documents Lower PostLower RI (SAIC 2004) RI Report Sites for 46, 76CS, 84, and 184 RI (SAIC 2007c) Sites 24, 76CS, 99, and 126 FS (SAIC 2010a)
. . .
– Preferred Preferred Alternative Soil – OffsiteSoil Disposal for Unrestricted Use Groundwater No Action
Site EcologicalAssessment HQs above 1 were estimated for Sites 37PS, 76CS, and 76OD. Given the small acreage (0.07 and 0.23 acres, respectively) at Site 37PS and 76OD, industrial and the of thesenature areas, it is unlikely that hawks, eagles, shrews, or robins wouldspend a large amount of time foraging there; therefore, the HQs greatly overestimate the risks to these species. As a result, ecological acceptable. risks are While HQs a few from metals remain above 1 using realistic more exposure assumptions at Site 76CS, the most elevated concentrations of metals were detected in soil borings among active railroad tracks. metal The concentrations in the grassy fields to the north and east of the railroad lines are (which more attractive to wildlife foraging for territory or cover) allwere their below respective ESVs. Wildlife exposure to elevated metal concentrations would be limited. Therefore, ecological acceptable risks are .
based screening - he likely future land related . Key Information ROD Each for . Key th risk assessmentwas -1 PAHs, t 2 Human Health Assessment sociated groundwater with are Table use risks were considered considered risks were use unacceptable, warranting further action. In addition, risks cancer exceed the target risk and range HIs exceed the target the of 1 for hypothetical and thus resident are considered unacceptable. A human heal not conducted for groundwater because detected constituents in the groundwater samples generally did not indicate site- contamination or concentrations exceeding health levels. Therefore, human health risks as acceptable. Human health risk assessment for soil indicates that risks industrial for and construction workers and recreational receptors at are belowor the target HI and the target within risk at allrange three sites. However, estimated cancer risks at the high are end of the target risk the for range industrial worker at Site 76CS. Due to this cancer risk approaching the upper bound of the target, coupled with uncertainty associated with the c for risks
Savanna Army Depot (Continued) Savann Depot Activity, a, Illinois Army Savanna
Detected Chemical Constituents VOCs, SVOCs, and metals
Media Sampled Soil and groundwater
Site Sites 37PS, 76CS, and 76OD
Savanna Army Depot, Final ROD 2-4 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
CL and CN
Supporting Documents Sites 24, 76CS, 99, and 126 FS (SAIC 2010a) RI Report the for Plant Areas and Remaining LRA Parcels (SAIC 2007b) Upper PostUpper RI Report (SAIC 2009a) Sites 5, 69, and FFS 184 (SAIC 2010b)
. . . .
Preferred Preferred Alternative Soil – No ActionSoil Groundwater – No Action Soil – OffsiteSoil Disposal for Unrestricted Use Groundwater – No Action
metal Site
EcologicalAssessment Antimony HQs for plants and shrews abovewere 1; however, given the infrequent detection of antimony (in 3 of 23 sample locations), to this exposure would be limited. Therefore, ecological acceptable risks are at this site. No HQs above 1. Therefore, the ecological acceptable risks are at this site.
ks industrial for . Key Information ROD Each for . Key th risk assessment -1 2 Human Health Assessment evaluated and found to be - PAHs (the risk drivers for this site), site), for this drivers risk (the PAHs Table overestimated due primarily to the use of conservative exposure concentrations and outdated toxicity values. Comparison of site concentrations to USEPA and IEPA residential soil values screening showed no exceedances the for chemicals responsible the majority for of the produce ingestion risk. Therefore, human health risks are acceptable at this site. Human health risk assessment indicates that ris workers, construction workers, and recreational receptors below are the risktarget range and the target HI. Produce ingestion cancer risks for hypothetical residents at the upper bound of the target risk range were re Human heal indicates that risks industrial for workers, construction workers, and recreational receptors are thewithin risktarget range and noncancer HIs beloware the target. However, due to cancer risk in the upper half of the target risk range for the industrial worker, coupled with uncertainty associated with the risk estimates for c the likely future land use risks were considered unacceptable, warranting further action. Cancer risks the for hypothetical receptors resident exceed the target cancer risk range consideredand are unacceptable.
Savanna Army Depot (Continued) Savann Depot Activity, a, Illinois Army Savanna Detected Chemical Constituents BTEX and PAHs and BTEX Metals, SVOCs, and explosives
Media Sampled Soil and groundwater Soil and groundwater
Site Site 126 Site 69
Savanna Army Depot, Final ROD 2-5 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
155, Building -
186, Building 707 CF 155, Building 729 CF - - Supporting Documents 729 CF Plant729 CF Drilling and Boostering Building, SVAD Plant Generator Building (URS 2009) SVAD Plant Drilling and Boostering Building Removal Site Evaluation and Engineering Evaluation/Cost Analysis (URS 2008a) Removal Action Construction SVADReport.
. .
Preferred Preferred Alternative Soil – No ActionSoil Groundwater – No Action
except for Site the ESV oxicity referenceoxicity
the HQs all for
the maximum sample EcologicalAssessment After the more realistic use area factors, exposure point concentrations, and diets were factored in detection. In addition, the presence of elevated lead in only one sample location and the arithmetic mean concentration below suggest that lead is not a concern at Site 155. Therefore, the ecological risks acceptable are at this site. ecoCOPCs t with value declined 1, below DNBP and lead. However, DNBP risks heavily are biased by
risk risk samples. The emediation was . Key Information ROD Each for . Key -1 2 and an HI of 0.006 for the 6 - Human Health Assessment 10 Table resident child. These risks at or are below regulatory targets and are considered acceptable. groundwaterThe risk assessment indicates no complete exposure pathway for workers recreational or receptors. For hypothetical residents exposed to groundwater, updated risk assessment methods indicate there no cancerare effects therefore (and no cancer risk) associated the with detected chemicals. noncancer The HQ for resident groundwater exposures is below the target HI of 1. Therefore, groundwater risks are considered acceptable. The soilThe risk assessment conducted prior to the soil removal action indicated that r necessary. Confirmatory sampling following removal action verified that remaining soil concentrations were thebelow residentialcleanup level except for three assessment residual for concentrations of chemicals exceeding the residential cleanup level resulteda cancer in risk of 1 ×
Savanna Army Depot (Continued) Savann Depot Activity, a, Illinois Army Savanna
Detected Chemical Constituents VOCs, SVOCs, explosives, and metals
Media Sampled Soil and groundwater
Site Site 155
Savanna Army Depot, Final ROD 2-6 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
008b) 155, Building -
186, Building 707 CF -
Supporting Documents Sites 46, 76CS, 84, and 184 RI Report (SAIC 2007c) Sites 5,69, and 184 FFS (SAIC 2010b) Removal Action Construction SVADReport. Plant729 CF Drilling and Boostering Building, SVAD- 186, Building Plant 707 CF Generator Building(URS 2009) SVAD Plant Generator Building Removal Site Evaluation and Engineering Evaluation/Cost Analysis (URS 2
. . . .
Preferred Preferred Alternative Soil – No ActionSoil Groundwater – No Action Soil – No ActionSoil Groundwater – No Action
Site EcologicalAssessment s) and the close proximity of ological pathways. exposure The leadThe HQ remained above 1 for robins using more realistic exposure assumptions; however, exposure of populations of robinsto elevated concentrations of lead would be extremely limited small due to the size associated the with site(0.018 acre Building 640. Therefore, ecological risks acceptable are at this site. Site 186 is an extremely small site and there were no complete ec Therefore, the ecological risks are acceptable at this site.
. Key Information ROD Each for . Key -1 2
Human Health Assessment evaluated and found to be - Table overestimated due primarily to use of conservative assu exposure mptions. Comparison of site concentrations to USEPA and IEPA residential soil screening values showed only limited exceedances for the chemicals responsible the for majority of the produce ingestion risk. Therefore, human health risks acceptable are at this site. Cancer risks industrial for workers, construction workers, and recreational receptors are acceptable. Following the FFS, produce ingestion risks for hypothetical residents were re soilThe risk assessment conducted prior to the soil removal action indicated that remediation was necessary.Confirmatory sampling following the removal action verified that remaining soil concentrations were below residential cleanup levels except for one sample collected thebelow excavation at a depth greater than 15 feet BLS. Because isthere no anticipated human exposuresoils to at this depth, soil risks considered are acceptable. groundwater,For detected constituents indistinguishable were from background. Therefore, risks from exposure to groundwater were not calculated receptor any for and groundwater risks considered are acceptable.
Savanna Army Depot (Continued) Savann Depot Activity, a, Illinois Army Savanna
Detected Chemical Constituents PAHs and metals VOCs, SVOCs, metals, and explosives
Media Sampled Soil and ndwatergrou Soil
Site Site 186 Site 184
Savanna Army Depot, Final ROD 2-7 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 t 252 s 246
255 e 245 W 247 115
d 112 111 234 249 R 117 e 108 k 109 114 243
200 s
n 119 i 107
222 h 233 121 106 218
S 125 220 Inset 127 23 226 202 224 Shinske Road 201 Site 69 Site 216 150 214 231 400
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Site 76CS Site r
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Site 37PS Site
29
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n 402 2 412 276 135 133 418 Site 76ODSite 140 1 West Road 406 SITE LOCATIONS 409 423 SAVANNA,ILLINOIS 145 Feet 54 413 55 RECORD OF DECISION 160
52 407
53 419
147 3rd H Street H 3rd 4th H Street H 4th 56 57
141 Bellvue Dam Dam Road Bellvue 146 58 410 51 424 SAVANNAARMY DEPOT ACTIVITY 50 FIGURE:2-1 414
h t PROJECT:\GIS_DATA\SVAD\Projects\Sites_24_76CS_99_126\ 10Sites ROD\Figure 2 Study FS Sites.mxd
u 420 o S e v 427 d A R 426 R
428 C H Old t 1,000 2,000 3,000
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607 639 C 605 638 608 611 634 610 614 635 631 Feet Site 126 Site 626 2,000 628 941
Shinske Road 625
CL Loop Site 184 Site 624 905 616 623 907 617 615 620 619 McIntyre Road 939 1,000 908 922 938 q 921 Site 24 Site 909 960 920 0 910
p o o L 155 Site ad se Ro G 919 Hou ange
Site 186 Site h
911 C CF 500 923 738 726 918 924 742 926
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925 744 917 Road G 735 745 760 729 722 758 764 749 715 712 716 714 721 751 750 711 701 776 700 757 717 761 762 702 SITE SITE 186 SITE SITE 76CS SITE 76OD SITE 126 SITE 155 SITE 184 707 770 769 765 753 767 768
774 CF Loop CF Perimeter Rd
LCL Road 1102
808 MISSISSIPPI RIVER
p SITE 24 SITE FEATURES 24 SITE 37PS SITE 69 INSTALLATION BOUNDARY INSTALLATION SITE 5 o Site Features 24 Site
Storage Shed o
807 L Legend 806 J Savanna Army Depot, Final ROD 2-8 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
2.3 COMMUNITY PARTICIPATION Supporting documents providing additional detail and information regarding field investigations, laboratory analyses and results, risk assessment, and closure details are available for public review through the SVDA Administrative Record at the following locations:
• Savanna Public Library 326 Third Street Savanna, IL 61074 • Hanover Public Library 204 Jefferson Street Hanover, IL 61041 • Savanna Army Depot SVDA Administrative Record Building 246 18935 B Street Savanna, IL 61074. The libraries are information repositories that contain only key documents relating to these sites. The full Administrative Record is available at SVDA. A notice of availability of these documents was published in the Savanna Times Journal, Galena Gazette, Dubuque Telegraph Herald, Prairie Advocate, and Clinton Herald in November and December 2012. A public comment period for the Proposed Plan was held from November 14, 2012 through December 14, 2012. In addition, a public meeting was held on December 6, 2012 at the Building 247 conference room at SVDA to present the Proposed Plan to a broader community audience than has been involved at the site. At this meeting, representatives from SVDA, USEPA, and IEPA were available to answer questions regarding concerns at the site. Written public comments were received on the Proposed Plan. The responsiveness summary is provided in Section 3 of this ROD. In addition, since 1995, Restoration Advisory Board (RAB) meetings that represent a cross-section of the community are held at SVDA quarterly. During these RAB meetings, the Army has apprised the community of the status of the ROD sites. 2.4 ENVIRONMENTAL SETTING SVDA is in northwestern Illinois adjacent to the Mississippi River in Jo Daviess and Carroll Counties. The Installation is in the central lowlands of the interior plains physiographic province. The Installation occupied 13,062 acres at the time of closure and is bordered by agricultural land to the north and east, the Apple River to the southeast, and the Mississippi River to the south and west. SVDA is encompassed on the Blackhawk, Illinois and Green-Island, Iowa U.S. Geological Survey (USGS) quadrangle maps (1952-53 revision, photo-revised 1975) approximately between coordinates 466,000 feet to 484,000 feet (east) and 2,006,000 feet to 2,017,000 feet (north) in the Illinois (west) State Plane Coordinate System (ISPCS). The majority of the northern and central portions of the Installation (Upper Post) are in Jo Daviess County, Illinois, and the southernmost acreage (Lower Post) is in Carroll County, Illinois. 2.5 SCOPE AND ROLE OF RESPONSE ACTION In 1989, an FFA was signed by the Army, IEPA, and USEPA. In 1995, SVDA was selected for closure under the Base Closure Act, as amended, and SVDA officially closed in March 2000. The 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 IEPA. There are 127 Installation Restoration Program (IRP) sites at SVDA with 62 of these sites having achieved response complete. Ten of these IRP sites are presented in this ROD.
Savanna Army Depot, Final ROD 2-9 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
The 10 sites presented in this ROD were evaluated in the RI, FS/FFS, RSE and EE/CA, and/or RACR completed between 1994 and 2011. Unacceptable human health risks were identified at four sites (Sites 37PS, 76CS, 76OD, and 126). Sites 37PS, 76CS, 76OD, and 126 have been recommended for soil excavation and disposal at an offsite facility, resulting in unrestricted land use at these sites. Sites 5, 24, 69, 155, 184, and 186 have no unacceptable human health risks and, as a result, no action is being taken at these sites. This ROD presents the final response for these sites. 2.6 SITE DESCRIPTIONS This section summarizes the characteristics of the 10 sites at SVDA, including the individual site history and summary of investigation and remediation results. Sites 5 and 69 are located in the Upper Post Area; Sites 37PS, 76CS, and 76OD are located within the CF Plant Area; and the remaining sites are located in the Lower Post Area. 2.6.1 Site 5 (Liquid Propellant Burn Area) The Liquid Propellant Burn Area (Site 5) is in the upper portion of the Installation on a prominent sand ridge adjacent to an unpaved gravel path that runs perpendicular to Shinske and West Roads. Site 5 initially was identified during the 1979 Installation Assessment as a burn site for red fuming nitric acid (RFNA) and unsymmetrical dimethylhydrazine (UDMH). The area reportedly was used for burning liquid RFNA and UDMH from 1960 to 1965 (USATHAMA 1979). Based on a review of aerial photographs, burning may have begun as early as 1955 (Dames & Moore 1994).
Site 5 – Liquid Propellant Burn Area The quantity of RFNA and UDMH burned at the site and the frequency of burning activities are unknown. According to a 1955 historical report, Army representatives had arranged a test of an RFNA disposal pit for viewing (SOD 1955). A former SVDA employee indicated that RFNA and UDMH may have been dumped at the site onto limestone blocks and not burned (Uangst 1989). Dames & Moore (1994) believe an aboveground open metal tank (approximately 1,500-gallon capacity) at the site may have been used to contain liquid propellant during burning. SVDA personnel questioned the use of a tank to store the liquid propellant prior to burning because UDMH is very reactive (Clarke 1995). The tank has a large valve over an outfall pipe that extends beneath the ground surface downslope from the tank. A small temporary sediment basin on the northeastern edge of the site received runoff from the outfall pipe extending from the metal tank upgradient of the basin. No other temporary or permanent drainage structures exist on the site or nearby (Dames & Moore 1994). Environmental Science and Engineering (ESE) (1982) and Dames & Moore (1994) conducted environmental sampling at Site 5. ESE (1982) collected one surface soil sample and analyzed the sample for base/neutral and acid extractables (BNAs), explosives, nitrate, phosphorus, and sulfate.
Savanna Army Depot, Final ROD 2-10 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
Bis(2-ethylhexyl)phthalate (B2EHP) was the only analyte detected in soil, at a concentration near the detection limit. Dames & Moore (1994) sampled soil, groundwater, and sediment at Site 5 in conjunction with the 1992 RI. Soil samples were collected along the side of the ridge, near the open metal tank, and one sample was collected from a point of outfall from the metal tank and analyzed for explosives, metals, anions, and BNAs. One groundwater monitoring well was completed in the bedrock aquifer at 46.5 feet below land surface (BLS). The well was positioned between the metal tank and the point of outfall from the tank, and the groundwater sample was analyzed for explosives, BNAs, and anions. One sediment sample was collected and analyzed for BNAs, metals, and anions. The following potential site-related contaminants were identified by Dames & Moore (1994): • Soil—Fluorene and phenanthrene • Groundwater—None • Sediment—Sodium. Dames & Moore (1994) concluded that the contaminant migration potential at Site 5 is limited because of: 1) the lack of identified contaminants in groundwater, 2) the low concentration of the detected contaminants, and 3) the low mobility of phenanthrene and fluorene. From December 1999 to June 2000, Science Applications International Corporation (SAIC) conducted field investigations at Site 5 to determine if residual contamination from burning activities was present. The existing groundwater monitoring well was redeveloped and sampled for VOCs, SVOCs, explosives, metals, anions, and pH. Carbon tetrachloride was detected above screening criteria. Soil samples were collected from multiple intervals in two soil borings drilled north of the burn area and in the center of the burn area depression and were analyzed for VOCs, SVOCs, explosives, and metals. In addition, one soil sample was collected and analyzed for pH. Site-related constituents detected above screening criteria were copper, lead, and zinc. 2.6.2 Site 24 (CF Plant Melt and Pour Facility) The CF Plant Melt and Pour Facility (Building 716) was used primarily between 1941 and 1945 to load fixed round ammunition with explosives. Melt and pour operations included heating solid (granular) ammonium nitrate and 2,4,6-trinitrotoluene (TNT) and pouring the explosives into casings or shells. During that time, three metal-lined concrete sumps, which were contained in sheds attached to the southern side of Building 716, were used to remove suspended solids from wastewater produced during the melt and pour operations. Wastewater containing TNT and other explosives was transported to the sumps and suspended solids contained in the solution were allowed to precipitate out. Wastewater then discharged to six concrete leaching pits immediately adjacent to Building 716. After World War II, from approximately 1948 to the mid-1950s, Building 716 was renovated and used as an explosive washout plant. During that time, wastewater from washout operations was transported through an open tile drain pipe and discharged to a leaching field approximately 1,500 feet southwest of Building 716 in a densely wooded area. The pipeline subsequently was removed and the trench housing has been backfilled. ESE (1982), Hunter/ESE (1989), and Dames & Moore (1995) conducted limited investigation activities at Site 24. The results confirmed the presence of site-related constituents in the groundwater downgradient from the Building 716 sumps and leaching pits, but did not delineate the nature and extent of the potential soil and groundwater contamination (Dames & Moore 1995).
Savanna Army Depot, Final ROD 2-11 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
Site 24 – CF Plant Melt and Pour Facility Dames & Moore conducted supplemental investigations of soil, groundwater, and surface water/ sediment between 1992 and 1994. Potential contaminant sources investigated included the six wastewater leaching pits, three sumps contained in the shed attached to the southern side of Building 716, the leaching field, an open ditch containing a clay-tile pipeline, and a suspected end-to-end trench. The following potential site-related contaminants were identified by Dames & Moore (1995): • Soil—Explosives within surface and subsurface soils in and surrounding the wastewater leaching pits and sumps • Groundwater—Explosives in the area downgradient from the wastewater leaching pits and sumps and within the vicinity of the leaching field. Dames & Moore (1995) concluded that discharges from previous TNT melt and pour and washout operations and explosives-contaminated soils underlying the area of the leaching pit and wastewater sump operations provide a potential source for groundwater contamination observed downgradient from the site and in groundwater underlying the leaching field. From 1998 through 2000, SAIC conducted field investigations at Site 24 to delineate explosives contamination in the groundwater by collecting 155 Hydropunch® groundwater samples. The Hydropunch® groundwater sampling was used to identify locations for monitoring wells. Six groundwater monitoring wells were installed at Site 24 during this field investigation. Groundwater samples collected from the existing and new monitoring wells were variably analyzed for VOCs, SVOCs, explosives, metals, pesticides/polychlorinated biphenyls (PCBs), and anions. Site- related metals detected in the monitoring wells were limited to antimony and silver. An isolated concentration of silver in one monitoring well exceeded human health screening criteria for groundwater. Concentrations of anions in the groundwater were below the Illinois Class I Groundwater Quality Standards (GQSs). Explosives and explosive breakdown products were detected in groundwater with concentrations of 1,3,5-trinitrobenzene (1,3,5-TNB), TNT, 2,6-dinitrotoluene (2,6-DNT), 2-amino-4,6-dinitrotoluene (2-A-4,6-DNT), 4-amino-2,6-dinitrotoluene (4-A-2,6-DNT), and cyclo-1,3,5-trimethylene- 2,4,5-trinitramine (RDX) exceeding human health screening concentrations. The maximum explosive concentrations in groundwater were detected predominantly in the western leaching field area. Explosives were not detected in the deep well, confirming that explosives have not substantially migrated to greater depths in the aquifer. Isolated concentrations of chloroform, trichloroethene (TCE), and benzo(k)fluoranthene exceeded human health screening concentrations. Seven pesticides were detected; however, no detections were at concentrations that exceeded screening levels.
Savanna Army Depot, Final ROD 2-12 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
In 2002, SAIC conducted decontamination and cleanup activities associated with three sumps in Building 716. Decontamination activities included removal of all residual liquid and sediments from each compartment within Sumps 1 through 3. After the residual materials were removed, the sidewalls and bottom of each sump compartment were cleaned and decontaminated using a hot water pressure washer. A soil remedial action at Site 24 was recommended based on the results of the Dames & Moore EE/CA (1995). In 2003, Cape Environmental Management, Inc. (CAPE) conducted a removal action at the leaching pits and sumps on the southern side of Building 716 (CAPE 2006). The action included removal of two groundwater monitoring wells; removal of overhead air, exhaust, and electrical piping and testing for explosives residue; excavation and stockpiling of overburden soil; removal of TNT- impacted soil; waste characterization; and confirmation sampling. In addition, underground piping, a distribution box, and six leaching pits were removed and the debris was steam cleaned prior to disposal. The TNT-impacted soil remediation objective targeted a maximum concentration of 44 mg/kg (based on worker exposure in an industrial setting). Analytical results from the final confirmation samples confirmed that the cleanup objectives were achieved (CAPE 2006). The project was completed in December 2003 with a total of 2,573 tons of explosives-impacted soil and demolition debris transported offsite and disposed of as nonhazardous soil special waste (CAPE 2006). Supplemental groundwater sampling was conducted in 2009 by SAIC to assess the current explosive concentrations and to establish baseline groundwater conditions for the FS remedial alternative evaluation. Two rounds of groundwater samples were collected and analyzed for explosives in June and September 2009 from existing Sites 24 and 99 monitoring wells. Explosive compounds were detected in the wells. An isolated concentration of 2,4-dinitrotoluene (2,4-DNT) exceeded the proposed IEPA GQSs during the September 2009 sampling round in MW-24-03. The remaining explosives constituents detected during the 2009 sampling events were below the proposed IEPA GQSs. Comparison of the 2009 data with historical data for Site 24 groundwater indicates that explosive concentrations have noticeable attenuation in MW-24-02, MW-24-03, and 302408 and nondetection of explosives in MW-24-10, which is farther downgradient at the site. Two of the explosive COCs (RDX and 2,6-DNT) were not detected during 2009 sampling rounds. In addition, the maximum detected concentrations of 2-A-4,6-DNT and 4-A-2,6-DNT were below the IEPA proposed GQSs. 2.6.3 Site 37PS (Pole Storage Area) The Pole Storage Area (Site 37PS) is used to store treated utility poles and is in an open area adjacent to Site 76CS, southeast of Building 703. During the EBS, a tar-like substance, suspected to be creosote, was observed dripping onto the exposed soil below the aboveground storage rack.
Site 37PS – Pole Storage Area
Savanna Army Depot, Final ROD 2-13 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
In 1998, SAIC collected soil samples from multiple intervals of five soil borings. One groundwater sample was collected using the Hydropunch® technique. Soil and groundwater samples were analyzed for SVOCs and metals. SVOCs and metals were detected at concentrations exceeding screening criteria. As a result of these findings, additional investigation activities were completed in 1999. Soil samples were collected from multiple intervals from four additional borings. Samples were analyzed for SVOCs and metals. A monitoring well was installed at Site 37PS because eight SVOCs were detected in samples collected at the soil-groundwater interface at concentrations that exceeded the screening criteria. The monitoring well was sampled in the fall of 1999, spring of 2000, and fall of 2001. The first round of samples was analyzed for SVOCs, metals, and anions. The second round of samples was analyzed for SVOCs, VOCs, metals, and anions. The third round of samples was collected as part of the Lower Post Shop Area groundwater evaluation and was analyzed for VOCs, SVOCs, metals, and herbicides. Eight site-related metals were detected in the surface soil. Arsenic was the only metal detected in the surface soil and beryllium was the only metal detected in the subsurface soil at concentrations that exceeded the screening criteria for protection of human health. Overall, inorganic constituents were detected at greater concentrations in the surface soil than in subsurface soil, indicating that metals are attenuating with depth. Five SVOCs were detected in the surface and shallow subsurface soil at concentrations that exceeded the protection of human health screening criteria. The Site 37PS soil boring data were compared to the data collected at Site 76CS and it was noted that the non-PAH SVOCs detected at Site 37PS were different from the non-PAH SVOCs detected at Site 76CS. This indicates that the non- PAH SVOCs were most likely due to the pole storage activities. The highest non-PAH SVOC concentrations detected did not exceed screening criteria for the protection of human health. Five metals (antimony, arsenic, nickel, selenium, and zinc) were detected in the surface and/or the subsurface soils at concentrations that exceed the migration to groundwater screening criteria. In general, metals concentrations decreased from the surface soil to the shallow subsurface soil. Twelve SVOCs detected in the surface and eight SVOCs in the shallow subsurface soil were at concentrations that exceed the migration to groundwater screening criteria. With the exception of one sample location, the SVOCs are predominantly confined to the surface soil with limited and inconsistent vertical distribution. Several inorganic constituents were detected in the groundwater samples but none was considered site related. No organic constituents were detected in any groundwater samples collected at Site 37PS either in the monitoring well samples or the Hydropunch® groundwater sample. Groundwater directly underlying Site 37PS, therefore, is presumed to be unaffected by historical activities conducted at Site 37PS. 2.6.4 Site 69 (Contaminated Waste Processor – Building 2215) The CWP (Site 69) is in the northern post area on the northeastern side of West Road. The CWP was a single-chamber, batch-feed furnace designed to incinerate low-level, explosives-contaminated, combustible material or to flash explosives-contaminated metals, consisting of a carbottom furnace, a batch-feed system, and an air pollution control system (APCS). The facility has concrete aprons with sumps in the center for unloading fuel oil for the CWP. Trenches are inside the building and drain into a sump (SAIC 1999). The majority of the waste materials incinerated in the CWP consisted of untreated wood, packing materials (e.g., cardboard boxes and paper), and fiber containers. These items potentially were contaminated with small amounts of explosives (SVDA 1985). Approximately 5,400 ammunition boxes were treated in the CWP between 1986 and 1993 (SVDA 1993a). During a small fraction of the
Savanna Army Depot, Final ROD 2-14 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
operating time, the CWP was used to flash metal items to remove traces of explosives prior to salvaging the metal. The cement pad under the baghouse at the Explosive Waste Incinerator (EWI)/CWP complex was identified as a collection point for RCRA hazardous waste in SVDA’s Waste Management Plan (SVDA 1992) and was used for approximately 10 years for collecting carbottom ash generated at the CWP (Clarke 1996).
Site 69 – Contaminated Waste Processor In June 1995, Q.C. Metallurgical Laboratory, Inc. conducted soil sampling activities at the former storage pad prior to the construction of Building 2220. Twelve soil samples were collected from six soil borings and analyzed for explosives, nitrocellulose, total metals, and toxicity characteristic leaching procedure (TCLP) metals. Nitrocellulose was detected in four soil samples, and TNT was detected in one surface soil sample. Barium, cadmium, chromium, lead, and silver also were detected in the soil samples. Results of the metals analysis indicated that no metals were present at concentrations above the TCLP limits (Q.C. Metallurgical Laboratory, Inc. 1995). SAIC conducted two field investigations at Site 69 to investigate the potential presence of chemical constituents in the soil as a result of storage and operating procedures at Building 2215. In the winter of 2000, surface soil samples were collected from 20 locations at Site 69. Metals, explosives, and pentachlorophenol (PCP) were present in the surface soil at concentrations that exceeded the screening criteria. In the spring and summer of 2002, soil samples were collected from four soil borings and three surface locations. In addition a Hydropunch® groundwater sample also was collected. Metals (antimony and selenium), an explosive (2-A-4,6-DNT), and SVOCs (N-nitrosodi-n-propylamine and PCP) were detected in the surface soil at concentrations that exceeded the screening criteria. Chemicals of potential concern (COPCs) were not detected in the subsurface soil above human health screening values. In addition, chemical constituents were not detected in the Hydropunch® groundwater sample. 2.6.5 Site 76CS (Former Coal Storage Area) The Former Coal Storage Area (Site 76CS) is on the Lower Post in a contiguous area between Building 117 (Ammunition Peculiar Equipment [APE] Shop) and Building 115 (Locomotive Roundhouse), continuing north along a railroad spur, and ending along the railroad tracks north of Building 129. Site 76CS is bounded to the south by Site 76FA and to the west by Sites 37PS, 37FS, 37GS, 76OD, and 76AD. Coal piles were identified within historical aerial photographs reviewed during the EBS. Site 76CS is no longer used for coal storage; however, coal fragments and coal dust were identified on the ground surface during the EBS.
Savanna Army Depot, Final ROD 2-15 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
Site 76CS – Former Coal Storage Area In 1998, SAIC collected soil samples from multiple intervals from the surface to the soil- groundwater interface in five soil borings at Site 76CS. Samples were analyzed for PAHs and metals. One groundwater sample was collected using the Hydropunch® technique. In 1999, soil samples were collected from five additional soil borings at the site. Samples were analyzed for PAHs, metals, and VOCs. Five soil samples were resampled from the 1998 soil borings and analyzed for VOCs. One soil boring drilled as part of the Site 76OD investigation was within the western boundary of Site 76CS. Samples were collected from multiple intervals from the surface to the soil-groundwater interface and analyzed for SVOCs, PCBs, and metals. The data from this one boring were included in the Site 76CS RI evaluation. In 2003, additional soil samples were collected from five soil borings from the surface and the subsurface at Site 76CS to delineate the horizontal extent of chemical constituents. Samples were analyzed for PAHs and metals. Site-related metals, SVOCs, and VOCs were detected within soils at Site 76CS. Antimony and arsenic were detected in the surface and arsenic in the shallow subsurface soil at concentrations exceeding the protection of human health screening criteria. Benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, and indeno(1,2,3-cd)pyrene were detected in the surface soil at concentrations exceeded protection of human health screening criteria. Benzo(a)pyrene and dibenzo(a,h)anthracene also were detected in the shallow subsurface soils at concentrations exceeding protection of human health screening criteria. The range of PAH concentrations in soil is consistent with the range of concentrations detected at adjacent Sites 37PS, 76AD (prior to remediation), 76OD, and 76RH. Antimony, arsenic, and selenium in the surface and arsenic and nickel in the shallow subsurface soils were detected at concentrations exceeding migration to groundwater screening criteria. Arsenic concentrations in soil attenuated with depth. The maximum concentration of nickel detected is below the maximum SVDA background nickel concentration. One site-related metal (arsenic) was detected in the Hydropunch® groundwater sample exceeding the human health screening criteria. In addition, metal concentrations in Hydropunch® groundwater samples tend to be biased high due to the turbidity of the sample. Ten SVOCs/PAHs in the surface and three PAHs in the shallow subsurface soils were detected at concentrations that exceeded migration to groundwater screening criteria. PAHs were not detected in the Hydropunch® groundwater sample or in monitoring well groundwater samples from wells adjacent to Site 76CS.
Savanna Army Depot, Final ROD 2-16 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
2.6.6 Site 76OD (Open Drum Storage Area) The Open Drum Storage Area (Site 76OD) is an open area north of Building 117 and east of Building 129. This site was used from approximately 1980 to 1985 to temporarily store closed drums containing miscellaneous hazardous materials. Between 20 and 30 55-gallon drums containing Stoddard solvent, used oil, and used coolant reportedly were stored in this open area (Churchwell and Biasi 1995, Sheehy 1995, Sheehy 1997). According to a SVDA employee, spills occurred due to improper handling, storage, and sampling of the drums. Records concerning the drum removal and sampling of the drums’ contents are unavailable (Sheehy 1995).
Site 76OD – Open Drum Storage Area In 1998, SAIC collected soil samples from multiple intervals in five soil borings. One Hydropunch® groundwater sample was collected. Soil and groundwater samples were analyzed for VOCs, SVOCs, PCBs, and metals. Metals, SVOCs, and PCBs were detected in soil at concentrations exceeding the human health screening criteria. As a result of these findings, an additional investigation was completed in 1999. Soil samples were collected from multiple intervals in four additional soil borings. Soil samples were analyzed for SVOCs, PCBs, and metals. Of the six site-related metal constituents detected in surface soil, only arsenic and lead were at concentrations that exceeded the protection of human health screening criteria. Arsenic and lead were not considered site related in subsurface soil, indicating that these metals are attenuating with depth. Of the 22 organic compounds detected in the surface soil at Site 76OD, 6 (5 PAHs and 1 PCB) were detected at concentrations that exceed the protection of human health screening criteria. The majority of the PAHs exceeding the human health screening criteria were detected in the northern portion of the site, adjacent to the railroad tracks. Of the 19 organic compounds detected in the subsurface soil, only benzo(a)anthracene and benzo(a)pyrene were detected at concentrations that exceed the protection of human health screening criteria. With the exception of benzo(a)pyrene, the majority of the organics detected at Site 76OD are limited to the surface interval and are attenuating with depth. Arsenic, cadmium, selenium, and zinc in the surface and selenium in the shallow subsurface soils were detected at concentrations exceeding migration to groundwater screening criteria. Constituents that exceeded the migration to groundwater criteria in the surface interval decreased below levels of concern within the first 2 feet of the subsurface soil. Eight SVOCs/PAHs in the surface and three SVOCs/PAHs in the shallow subsurface were detected at concentrations that exceeded migration to groundwater screening criteria. The organic constituents detected at Site 76OD that exceeded the migration to groundwater screening criteria generally were limited to the surface and shallow subsurface intervals. In addition, organic constituents detected during Hydropunch® groundwater sampling did not exceed the human health screening criteria.
Savanna Army Depot, Final ROD 2-17 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
Nine inorganic constituents were detected in the Hydropunch® groundwater sample but none was considered site related. One VOC (toluene) was detected in the Hydropunch® groundwater sample; however, the concentration of toluene did not exceed the human health screening criteria. Groundwater directly underlying Site 76OD appears to be unaffected by historical activities conducted at the site. 2.6.7 Site 126 (CN Plant Boiler Building USTs, Building 502) Site 126 is approximately 0.29 acres and is located in an open area between the CN Loop and CN Service Road in a small area to the west of Building 502. The CN Plant Boiler Building, Building 502, was constructed in 1942 as a boiler building to provide steam heat to all structures within the CN Plant. The EBS noted that four 80,000-gallon concrete USTs were constructed in place in 1942, west of Building 502. In 1993, SVDA solicited the State of Illinois on the proper procedures for taking these tanks out of service. The State of Illinois Fire Marshal indicated that the tanks were considered field-constructed for the onsite storage and consumption of heating oil; therefore, the tanks were not covered by the state and Federal UST regulations (SVDA 1993a) and could be abandoned as SVDA deemed necessary. In May 1997, the tanks were cleaned and filled with sand (Straight 1998).
CN Plant Boiler Building USTs, Building 502 (Site 126) IEPA reviewed the 1993 SVDA memorandum (SVDA 1993b) and indicated that although the tanks are exempt from certain notification and reporting requirements, they were still subject to state requirements for overfilling and spill reporting and cleanup (Illinois Administrative Code [IAC] 170.400, 170.590 through 170.610). In addition, Sections 12(a) and 12(d) of the Illinois Environmental Protection Act may apply. IEPA also indicated that Federal RCRA requirements pursuant to 40 Code of Federal Regulations (CFR) 280, Subpart F also may still apply (IEPA 1997). In 2000, SAIC collected soil samples from multiple intervals between the bottom of the USTs and the soil-groundwater interface in four soil borings. In addition, one groundwater sample was collected using the Hydropunch® technique. All samples were analyzed for benzene, toluene, ethylbenzene, and xylenes (BTEX) and PAHs. In 2001, five additional soil borings were sampled with soil samples collected from multiple intervals between the surface and soil-groundwater interface and analyzed for BTEX and PAHs. One monitoring well was installed upgradient (north) of the site and one was installed on the downgradient (south) side of the site to characterize potential contamination in the groundwater. Two rounds of groundwater samples were collected and analyzed for BTEX and PAHs. Five PAHs (benzo[a]anthracene, benzo[a]pyrene, benzo[b]fluoranthene, dibenzo[a,h]anthracene, and indeno[1,2,3-cd]pyrene) were detected above the protection of human health and migration to
Savanna Army Depot, Final ROD 2-18 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
groundwater screening criteria in soil. In addition, benzo(k)fluoranthene was detected at concentrations above the migration to groundwater screening criteria. Concentrations of PAHs generally decrease with depth and PAHs tend to adsorb to the soil and do not migrate readily. PAHs were not detected at depths greater than 26 feet BLS in an area where depth to groundwater is 45 to 50 feet BLS. In addition, the PAHs were not detected in the monitoring well samples, indicating that the PAHs have not migrated to groundwater at the site. BTEX constituents were detected in the soil; however, concentrations did not exceed any of the screening criteria. Toluene and xylene were detected in the Hydropunch® groundwater sample; however, BTEX constituents were not detected in the monitoring well installed near the Hydropunch® groundwater location. The monitoring well results are considered to better represent the groundwater quality beneath the site and indicate that groundwater underlying the site is not impacted by the Site 126 UST activities. The absence of groundwater contaminants adjacent to the USTs is an indication that a large-scale release from the tanks has not occurred. The tanks have been cleaned and filled with sand and do not pose a threat of future release. Because the tanks do not have a history of leakage, the likely areas affected by potential spillage during heating oil transfers are the areas surrounding the tanks. 2.6.8 Site 155 (CF Plant Drilling and Boostering Building – Building 729) The CF Plant Drilling and Boostering Building, Building 729, was constructed in 1941 on CF Loop Road (SVDA 1979). Drilling was conducted as part of the CF Plant melt and pour operations, which included drilling explosives to create a cavity for the fuzes (Robinson 1996). Explosive dust (nitroaromatic/nitramine) from drilling operations was collected in one of two primary collection units by a vacuum line that was connected to the drill bit (Robinson 1996). Building 731 (Site 156) and Building 734 (Site 159) were the primary vacuum buildings and Building 776 (Site 175) was the vacuum collector building with three hoppers. Compressors associated with the vacuum lines were in Building 732 (Site 157) and Building 733 (Site 158). A historical map indicated that a concrete settling tank with a baffle system was northwest of Building 731 (SOD 1941). A historical report indicated that the primary collection unit was replaced with a wet wash system in the early 1950s (SOD 1953b).
Site 155 Settling Tank Historical maps indicate that Building 729 also contained a dark room and an X-ray machine (SOD 1953a and SAD 1966). It is assumed that hazardous chemicals (i.e., developers and fixers) could have been stored and used within the building. Prior to base closure, Building 729 was used to store small quantities (less than 10 gallons total) of paints and thinners used to renovate ammunition cans in Building 742 (Clarke 1996). During the EBS, no spills in Building 729 were identified (SAIC 1999). A
Savanna Army Depot, Final ROD 2-19 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
SVDA employee indicated that historical operations in Building 729 could have released explosives and propellant through the dust collection system (Robinson 1996). SAIC and URS conducted environmental sampling at Site 155. SAIC completed two phases of investigation in 2000 (Phase I) and 2001 (Phase II) to assess the presence of potential chemical constituents at Site 155 as a result of historical activities and to determine if chemical constituents exist at concentrations that pose an unacceptable risk to human health or the environment under the current or future land use. In 2006, URS conducted an additional investigation to provide data necessary to prepare the RSE and EE/CA (URS 2008a). During the SAIC Phase I investigation, three soil borings were sampled. In addition, one Hydropunch® groundwater sample was collected at the site. During the Phase II investigation, five additional soil borings were sampled. One groundwater monitoring well was installed and two rounds of groundwater sampling were conducted. All soil samples were analyzed for VOCs, SVOCs, metals, and explosives. Groundwater samples also were analyzed for anions. In addition, one sediment sample was collected from the settling tank and a water sample was collected from the concrete sump and analyzed for VOCs, SVOCs, explosives, metals, and anions. In addition to the Site 155 Hydropunch® groundwater sample, SAIC conducted an extensive Hydropunch® groundwater survey within the CF Plant Area as part of the Site 24 investigation. The objective of the investigation was to determine the extent of explosives constituents and VOCs in groundwater within the CF Plant Area. Four Hydropunch® samples were collected near the Site 155 investigation area. No VOCs or explosives were detected above screening criteria at these locations. URS conducted field investigation activities in 2006 and included soil and groundwater sampling. Ten soil samples and one groundwater sample were collected. Soil and groundwater samples were analyzed for SVOCs and explosives. Based on the SAIC and URS investigations, 11 SVOCs and 4 nitroaromatic/nitramine compounds were detected in surface soil samples at concentrations exceeding screening criteria. Five metals were detected at concentrations above the applicable screening criteria. Exceedances were concentrated in the area surrounding Building 733. Two SVOCs and TNT were detected in subsurface soil samples at concentrations exceeding screening criteria. No VOCs were detected above screening criteria in soil. In Hydropunch® groundwater samples, VOCs and SVOCs were detected above reporting limits but below the Illinois Class 1 standard. Lead and manganese were detected above the Illinois Class 1 standard. In groundwater monitoring well samples, no VOCs or metals were detected above reporting limits. SVOCs and nitroaromatics/nitramines were detected above reporting limits but below the Illinois Class 1 standards. The variability in metals detections between the Hydropunch® and monitoring well samples is attributed to turbidity associated with the Hydropunch® sampling. No VOCs, SVOCs, metals, or nitroaromatics/ nitramines were detected above screening criteria in the settling tank sediment. VOCs and nitroaromatics/nitramines were detected in the Building 732 sump water above reporting limits. Based on site characterization at Site 155, it was determined that SVOCs and nitroaromatics in the surface soil posed a potential risk to human receptors. Surface soil exceedances were concentrated in the area surrounding Building 733 (URS 2008a). In July 2008, a phased removal action was conducted at Site 155. The excavated area covered approximately 2,148 square feet to a depth of 2 feet BLS. Approximately 160 cubic yards of soil were excavated and transported offsite. A total of 15 confirmation soil samples were collected from the remediation areas of Site 155. After comparing the individual concentrations of the 15 confirmation soil samples to the cleanup criteria, 3 samples exceeded Tiered Approach to Corrective Action Objectives (TACO) Tier I Soil Remediation Objectives for residential property for benzo(a)pyrene and 2,4-DNT (URS 2009).
Savanna Army Depot, Final ROD 2-20 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
2.6.9 Site 184 (CL Plant Compressor Building – Building 640) The CL Plant Compressor Building (Building 640) (Site 184) was constructed in 1945 northwest of the Receiving, Inspection, and Painting (RIP) Building (Building 642) (SVDA 1979). A SVDA employee indicated that, based on operations in Building 640, oil could have been released in the building (Robinson 1996). Site 184 is composed of Building 640, an 11- by 17-foot building, and the surrounding area. The area is bounded to the north and east by Buildings 639 and 642, which are joined together with Site 184 (Building 640) in the resulting corner. In the summer of 1999, a visual inspection of Site 184 was conducted to identify potential sources of contamination. During the inspection, it was noted that a deteriorated drum was adjacent to the northern side of Building 640. The drum had been used to collect effluent material associated with the operation of the compressor. Due to the deteriorated condition of the drum, it was determined that chemicals associated with the compressor operation in the building may have been released to the environment.
Site 184 Building 640 Two field investigations were conducted at Site 184 to determine if residual chemical constituents from the compressor operations were present above media-specific screening criteria. The winter 2000 investigation activities included removal and disposal of the drum and all stained or discolored soil in the area surrounding Site 184. One surface soil sample was collected from the bottom of the excavation below the previous drum location. In the fall of 2003, soil samples were collected from four soil borings in and surrounding the original drum and excavation area. Metals (antimony, lead, and selenium) in the surface soil were the only constituents that exceeded the screening criteria. 2.6.10 Site 186 (CF Plant Generator Building – Building 707) Building 707, the CF Plant Generator Building (Site 186), was constructed in 1941 southwest of the CF Heating Plant, Building 704, on CF Melt and Loop Road. The building was used in the generation of power for the CF Plant. The building utility maps indicate that effluent floor drains lead to a leaching pit approximately 5 feet northeast of the building (SOD 1973). Construction details of the leaching pit were unavailable; however, during an SAIC inspection, it was noted that the pit was constructed with concrete block and mortar walls that extend to approximately 4 feet BLS. A SVDA employee indicated that, based on operations in Building 707, oil could have been released in the building (Robinson 1996). Site 186 is situated between service roads and buildings and the leaching pit is on the north side of Building 707. The site is approximately 174 square feet. The leaching pit is at the center of the investigation site approximately 5 feet from the building.
Savanna Army Depot, Final ROD 2-21 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
Buildings 706 and 707 and Leaching Pit Two field investigations were conducted by SAIC in 2000 and 2001 at Site 186 to investigate the potential presence of chemical constituents as a result of potential spills within Building 707 that would have been directed to the leaching pit. In addition, the investigations were conducted to determine if chemical constituents exist in the soil or groundwater at concentrations that pose an unacceptable risk to human health or the environment under current or future land use. During the 2000 Phase I investigation activities, one soil boring, one sediment, and one Hydropunch® sample were collected. One soil boring was completed at Site 186 adjacent to the leaching pit and samples were collected from below the level of the leaching pit, the soil-groundwater interface, and one intermediate depth. A sediment sample was collected from inside the leaching pit. In addition, one Hydropunch® groundwater sample was collected. Due to VOCs, SVOCs, PCBs, and metals detected during the Hydropunch® sampling, one monitoring well was installed and two rounds of samples were collected in the fall of 2001 and spring of 2002. Samples were analyzed for VOCs, SVOCs, PCBs, and metals. As a result of Site 186 being located within the CF Plant (Site 24), groundwater samples also were analyzed for explosives. Further soil sampling could not be conducted during the Phase II investigation due to high-voltage power lines buried in the area and the inability to obtain a utility clearance. Seven site-related metals (predominantly arsenic, copper, and iron) were detected in soil at concentrations exceeding screening criteria. Soil conditions at Site 186 are slightly alkaline (pH of 7.83), which reduces the potential for mobility for many metals. Four of the seven metals were site related in the Hydropunch® groundwater sample (only lead exceeded the human health screening criteria); however, concentrations are biased high. No site-related metals were detected in the groundwater monitoring well sample. One PCB (Aroclor 1260) was detected in soil at concentrations exceeding screening criteria. Aroclor 1260 was detected in both soil samples from the bottom of the leaching pit; however, Aroclor 1260 was not detected deeper than 4 feet BLS in the soil column. Aroclor 1260 was not detected in the Hydropunch® groundwater sample and no organic constituents were detected in the groundwater monitoring well sample. The constituents at this site were characterized to the extent possible. In July 2008, a removal action was conducted at Site 186. The excavated area covered approximately 314 square feet to a depth of 15 feet BLS directly below the sump. Approximately 55 cubic yards of soil were excavated and transported offsite. A total of 10 confirmation soil samples were collected from the remediated area at Site 186. Arsenic was above the TACO Tier I Soil Remediation Objectives for residential property for one sample collected below the 15-foot excavation depth (URS 2009).
Savanna Army Depot, Final ROD 2-22 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
2.7 HISTORICAL AND POTENTIAL FUTURE LAND USES SVDA was a 13,062-acre Installation that closed in March 2000. The SVDA property included 923 buildings, many of which are ammunition storage igloos or other storage facilities, and also includes industrial plant areas (the CN Plant, the CL Plant, the CF Plant, and the TNT Washout Facility). An inventory of land use at SVDA in 1975 found that of the total 13,062 acres, 300 acres consisted of improved grounds (e.g., lawns, ballfields, parade and drill grounds, and landscape plantings); 1,005 acres consisted of semi-improved grounds (e.g., production facilities, isolated mission activities, firebreaks, road and utility borders, and a heliport facility); 5,329 acres consisted of unimproved grounds (e.g., roads, buildings and structures, and agricultural leases); and 6,470 acres consisted of woodlands (Dames & Moore 1994, SAIC 1999). Historical industrial activities on the Installation occurred on a large scale within the CF, CL, and CN Plant areas and to a lesser extent within the shop areas on the Lower Post. Recreational land uses on the Installation have consisted of hunting, fishing, and boating. Fishing was conducted in Crooked Slough, the Apple River, and the Mississippi River. Although Crooked Slough lies entirely within SVDA boundaries and fishing access is legally restricted to SVDA personnel and other approved users, in practice the public does access the area for fishing. Commercial fishing is permitted in the portion of the Mississippi River bordering SVDA. A variety of wildlife species are found on the Installation and hunting is allowed by permitted hunters. Designated preservation areas, such as Bellevue State Park, the Upper Mississippi River Wildlife and Fish Refuge, and the Green Island State Wildlife Management Area, are near the Installation. Agricultural land use in the immediate vicinity of the Installation consists of livestock (i.e., cattle) and crop farming (i.e., corn, soybeans, wheat, hay, and oats). The Local Redevelopment Plan (ERA 1997) and Reuse Plan Update (MSA 2005, revised by SAIC 2012) have identified a variety of reuse alternatives for the land and facilities at SVDA. The majority of the Lower Post and Plant Areas of the Installation are proposed for future commercial/industrial use. The Mississippi River adjacent to the Lower Post, the area of Ordnance School Lake in the southeastern corner of the facility, and a southeastern portion of the facility adjacent to the Apple River are designated for recreational use under the control of the U.S. Fish and Wildlife Service (USFWS). The identified future land use for the Upper Post is projected to be primarily recreational with properties administered by USFWS and the Illinois Department of Natural Resources (IDNR). Based on the LRA land use plan, all of the ROD sites with the exception of Sites 5, 69, and a portion of Site 24 will continue to be used for industrial/commercial purposes, which exclude uses such as onsite company day care centers, recreation areas, or other occupancy uses that are incompatible with industrial activity or are tantamount to residential occupancy. Residential land use is currently prohibited by either the LRA land use plan (Sites 37PS, 76CS, 76OD, 126, 155, 184, 186, and a portion of Site 24) or USFWS plan (Sites 5, 69, and a portion of Site 24) for the property. Sites 5, 69, and a portion of Site 24 will be transferred to USFWS for operation as part of the Lost Mound Unit of the Upper Mississippi River National Wildlife and Fish Refuge. As part of the refuge, the site will be managed for wildlife protection and public use. 2.8 SUMMARY OF SITE RISKS Data screening and human health and ecological risk assessments were conducted for the ROD sites. These evaluations are summarized below. 2.8.1 Screening Evaluation As part of the RI process, screening evaluations were conducted at all of the 10 sites to compare site concentrations to background concentrations and regulatory health-based screening values. The results of the data screen were used to: 1) evaluate the nature and extent of site-related chemical constituents, 2) conduct a screening-level human health risk assessment and/or select COPCs to be
Savanna Army Depot, Final ROD 2-23 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
evaluated in a human health risk assessment, and 3) select ecological chemicals of potential concern (ecoCOPCs) for the screening-level ecological risk assessment (SERA). The data screen has four components, which are described below: • Background Comparison—Comparison of site and background data to distinguish naturally occurring metal constituents from metals that are present as a result of activities conducted at the site; all detected nonmetal constituents are considered site related. • Human Health Screen—Comparison of site concentrations to risk-based concentrations protective of human health in a residential setting (USEPA Region 9 PRGs [USEPA 2000, 2002, and 2004] and IEPA TACO Tier I remediation objectives [IEPA 2001 and 2002]) and an additivity screen to account for simultaneous exposure to multiple chemicals. • Ecological Screen—Assessment of habitat; determination of the presence of persistent, bioaccumulative, and toxic (PBT) chemicals; and comparison of site concentrations to screening values protective of the environment. • Migration to Groundwater Screen—Comparison of site soil concentrations to USEPA soil screening levels (USEPA 2000, 2002, and 2004) or TACO Tier I remediation objectives (IEPA 2001 and 2002) to assess the potential for leaching and migration of soil constituents to groundwater. 2.8.2 Human Health Risk Assessment For all of the sites in this document, site concentrations exceeded one or more of the conservative screening criteria; therefore, baseline human health risk assessments were conducted. Human health risk assessments were conducted for each ROD site to estimate the human health risk associated with potential exposure to chemicals detected at the site. Based on the LRA land use plan, Sites 24 (a portion), 37PS, 76CS, 76OD, 126, 155, 184, and 186 will continue to be used for industrial/commercial purposes. Sites 5, 69, and the remaining portion of Site 24 will be used for recreational purposes. No residential or agricultural land use is expected at any of the sites. Sites 5, 69, and a portion of Site 24 will be transferred to USFWS for operation as part of the Lost Mound Unit of the Upper Mississippi River National Wildlife and Fish Refuge. As part of the refuge, the site will be managed for wildlife protection and public use. The human health risk assessment evaluated the potential for adverse health effects for individuals who work in an industrial or construction setting (such as industrial, construction, maintenance, and security workers) and for children and adults who participate in recreational activities at the site (such as hiking and bird watching). In addition, the human health risk assessment evaluated the potential for adverse health effects for hypothetical residents at the sites (this scenario is conservative and is hypothetical because the LRA land use plan does not include residential reuse of these sites). The soil exposure pathways evaluated include ingestion of contaminated media (e.g., soil, produce), physical contact with contaminated media (i.e., dermal contact), and inhalation of contaminants in dust or vapors in the air. Groundwater exposure pathways include ingestion (assuming the groundwater is the source of drinking water for hypothetical residents) and dermal contact with the groundwater and inhalation of vapors while the resident is bathing or showering. USEPA has established target risk levels for use in determining the need for site remediation. Human health risk is expressed as the potential for developing cancer or adverse noncancer health effects. For noncancer effects, the USEPA target is a hazard index (HI) of 1. If a hazard quotient (HQ) or the HI is greater than 1, the potential for adverse health effects is of concern. For cancer effects, the target risk range has been set at 1 × 10-6 to 1 × 10-4. Lead exposures are assumed to pose an unacceptable risk if more than 5 percent of the exposed children or fetuses (of adult female workers) experience a blood lead level in excess of the 10 μg/dL blood lead level of concern.
Savanna Army Depot, Final ROD 2-24 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
The human health risk assessment results are summarized below and in Appendix A: • Site 5—Risks for industrial workers, construction workers, and recreational receptors are below the target risk range and the target HI. Residential cancer risks are in the lower half of the target risk range. The soil risk driver, benzo(a)pyrene, is below the IEPA residential screening value and the groundwater risk driver, carbon tetrachloride, is below the TACO Tier I groundwater remediation objective, Illinois GQS, and Federal maximum contaminant level ( MCL) for groundwater. Therefore, human health risks are acceptable at this site. • Site 24—The soil risk assessment conducted prior to the soil removal indicated that remediation was necessary. Confirmatory sampling following the soil removal action verified that remaining soil concentrations were below the industrial/commercial cleanup level. One sample slightly exceeded residential screening criteria. The baseline groundwater risk assessment indicated cancer risks for hypothetical residents in the upper half of the target risk range were unacceptable. However, the re-evaluation of the baseline groundwater risks indicated risks were overestimated. In addition, the results of the 2009 supplemental sampling indicated attenuation of groundwater concentrations largely below proposed IEPA GQSs and USEPA tapwater regional screening levels (RSLs), and human health risks likely falling at the low end of the target cancer risk range. The results of the soil removal, risk re-evaluation, and supplemental sampling indicate risks are acceptable for soil and groundwater at this site. • Sites 37PS, 76CS, and 76OD—The human health risk assessment for soil indicates that risks for industrial and construction workers and recreational receptors are at or below the target HI and within the target risk range at all three sites. However, estimated cancer risks are at the high end of the target risk range for the industrial worker at Site 76CS. Due to this cancer risk approaching the upper bound of the target, coupled with uncertainty associated with the risks for carcinogenic polynuclear aromatic hydrocarbons (cPAHs), the likely future land use risks were considered unacceptable, warranting further action. In addition, cancer risks exceed the target risk range and HIs exceed the target of 1 for the hypothetical resident and thus are considered unacceptable. The soil COCs associated with the planned industrial/commercial future land use of these sites are arsenic, benzo(a)pyrene, benzo(b)fluoranthene, and dibenzo(a,h)anthracene. Benzo(a)anthracene also is a COC for Site 76CS. A human health risk assessment was not conducted for groundwater because detected constituents in the groundwater samples generally did not indicate site-related contamination or concentrations exceeding health-based screening levels. Therefore, human health risks associated with groundwater are acceptable. • Site 69—The human health risk assessment indicates that risks for industrial workers, construction workers, and recreational receptors are below the target risk range and the target HI. Produce ingestion cancer risks for hypothetical residents at the upper bound of the target risk range were re-evaluated and found to be overestimated due primarily to use of conservative exposure concentrations and outdated toxicity values. Comparison of site concentrations to USEPA and IEPA residential soil screening values showed no exceedances for the chemicals responsible for the majority of the produce ingestion risk. Therefore, human health risks are acceptable at this site. • Site 126—The human health risk assessment indicates that risks for industrial workers, construction workers, and recreational receptors are within the target risk range and noncancer HIs are below the target. However, due to cancer risk in the upper half of the target risk range for the industrial worker, coupled with uncertainty associated with the risk estimates for cPAHs (the risk drivers for this site), the likely future land use risks were considered unacceptable, warranting further action. Cancer risks for the hypothetical resident receptors exceed the target cancer risk range and are considered unacceptable. The soil COCs for the planned industrial/commercial future land use of this site are benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, and indeno(1,2,3-cd)pyrene.
Savanna Army Depot, Final ROD 2-25 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
• Site 155—The soil risk assessment conducted prior to the soil removal action indicated that remediation was necessary. Confirmatory sampling following removal action verified that remaining soil concentrations were below the residential cleanup level except for three samples. The risk assessment for residual concentrations of chemicals exceeding the residential cleanup level resulted in a cancer risk of 1 × 10-6 and an HI of 0.006 for the resident child. These risks are at or below regulatory targets and are considered acceptable. The groundwater risk assessment indicates no complete exposure pathway for workers or recreational receptors. For hypothetical residents exposed to groundwater, updated risk assessment methods indicate there are no cancer effects (and therefore no cancer risk) associated with the detected chemicals. The noncancer HQ for resident groundwater exposures is below the target HI of 1. Therefore, groundwater risks are considered acceptable. • Site 184—Cancer risks for industrial workers, construction workers, and recreational receptors are acceptable. Following the FFS, produce ingestion risks for hypothetical residents were re-evaluated and found to be overestimated due primarily due to use of conservative exposure assumptions. Comparison of site concentrations to USEPA and IEPA residential soil screening values showed only limited exceedances for the chemicals responsible for the majority of the produce ingestion risk. Therefore, human health risks are acceptable at this site. • Site 186—The soil risk assessment conducted prior to the soil removal action indicated that remediation was necessary. Confirmatory sampling following the removal action verified that remaining soil concentrations were below residential cleanup levels except for one sample collected below the excavation at a depth greater than 15 feet BLS. Because there is no anticipated human exposure to soils at this depth, soil risks are considered acceptable. For groundwater, detected constituents were indistinguishable from background. Therefore, risks from exposure to groundwater were not calculated for any receptor and groundwater risks are considered acceptable. 2.8.3 Ecological Risk Assessment SERAs were conducted for each site to estimate the potential adverse effect to ecological receptors resulting from exposures to chemicals detected at the sites if no remedial action were taken. A summary of the SERA for each site is presented in Appendix B. The first level of evaluation in the SERA included one or more of the following components: an analysis of habitat to determine if the quality and quantity were sufficient to support wildlife (referred to as a habitat screen), determination of the presence of PBT chemicals (referred to as a PBT chemical screen), and a comparison of maximum site concentrations to screening values (ecotoxicity screen) protective of the environment resulting in the identification of ecoCOPCs (Appendix B). When ecological habitat and PBT chemicals and/or ecoCOPCs were present, further evaluation was conducted using food-chain modeling. The food-chain modeling takes into account site data, available information on the toxicity of site chemicals to wildlife, and the wildlife receptor’s intake of a site chemical through consumption of food and soil using very conservative assumptions. Representative wildlife receptors evaluated included shrews, robins, hawks, and eagles. In addition, the exposure of terrestrial plants to PBT chemicals and ecoCOPCs was evaluated at Sites 5 and 69 because these sites are designated for transfer to USFWS. Burrowing animals were evaluated at sites where inhalation of VOCs was a potential pathway. For each wildlife receptor, an HQ was calculated for PBT chemicals and ecoCOPCs. An HQ of less than 1 indicates that adverse effects for wildlife receptors or terrestrial plants would not be expected. Ecological risk for Sites 5, 69, 155, and 184 were acceptable based on the low concentration of constituents detected on the sites. In addition, Sites 5 and 184 were small in size and Sites 69 and 155 only had isolated concentrations of constituents within the site boundaries, therefore limiting the exposure of wildlife. Based on previously remediated soils at Site 24 and groundwater migration to the Mississippi River not being a concern, ecological risks were found to be acceptable. Wildlife would have limited
Savanna Army Depot, Final ROD 2-26 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
exposure to contaminants at Sites 37PS and 76OD, which are both small in size and industrial in nature. The highest detected concentrations of metals at Site 76CS occurred in between the railroad tracks, thus limited exposure to contaminants. There were no HQs above 1 for Site 126. Ecological risks were found to be acceptable at Site 186 due to no complete receptor pathways indicating that wildlife are not exposed to constituents. Therefore, based on the findings of the SERAs, ecological risks at the 10 sites are acceptable. 2.9 REMEDIAL ACTION OBJECTIVES The human health and ecological risk assessments concluded that no action is required for six sites (Sites 5, 24, 69, 155, 184, and 186). For the four sites requiring remedial actions (Sites 37PS, 76CS, 76OD, and 126), remedial action objectives (RAOs) were developed to specify the requirements that the remedial action alternative must fulfill to protect human health and the environment from the COCs identified in soil. The human health risks driving the identification of COCs in this ROD are those risks associated with the current and planned future use of the sites. At the four remedial action sites (Sites 37PS, 76CS, 76OD, and 126), the worker risks are the focus, because the current and planned future use is industrial/commercial. The RAOs will be protective of both the industrial and construction workers. Future residential land use is considered hypothetical because this is not a part of the current or planned future land use of the sites. The RAOs for soil at Sites 37PS, 76CS, 76OD, and 126 are as follows: • Reduce soil contamination (where applicable) to meet human health preliminary remediation goals (PRGs) and acceptable risk levels for the planned future land use (i.e., industrial/commercial) • Prevent human exposure to contaminated soil that would cause unacceptable risk. 2.10 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS ANALYSIS The identification and evaluation of ARARs is an integral part of the FS process in complying with CERCLA and SARA. This section lists the available Federal and state chemical- and action-specific ARARs. No location-specific ARARs exist for the ROD sites, only to-be-considered (TBC) guidance. Part 121 of CERCLA specifies that remedial actions for cleanup of hazardous substances must comply with requirements or standards under Federal or more stringent state environmental laws that are applicable or relevant and appropriate to the hazardous substances or circumstances at a site. Protection of human health and the environment is addressed by implementing ARARs. In addition, Army Regulations (ARs) 200-1 and 200-2 prescribe Department of the Army (DA) policies, procedures, and responsibilities to protect, preserve, and restore the quality of the environment. The selection of ARARs is dependent on the hazardous substances at a site, the physical site characteristics and geographic location, and the actions selected as a remedy, and are addressed by chemical-, location-, and action-specific ARARs, respectively (USEPA 1988). The remedial actions developed as part of the FS were analyzed for compliance with Federal and State of Illinois environmental regulations. The remedial action process involves the initial identification of potential requirements and the evaluation of the potential requirements for applicability or relevance and appropriateness. Chemical-specific ARARs are selected to set protective remediation levels for the COCs. These requirements include chemical-specific, health- or risk-based concentration limits, or discharge limitations in various environmental media for specific hazardous substances, pollutants, or contaminants. These requirements generally establish protective cleanup levels for COCs in the designated media or a
Savanna Army Depot, Final ROD 2-27 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
safe level discharge that may be established when considering a specific remedial activity. Whether potential chemical-specific ARARs are used toward establishing cleanup levels for the site will depend on their applicability to the chosen remedial action alternative. No chemical-specific ARARs exist for soil only TBC guidance. Location-specific ARARs set restrictions on the conduct of remedial activities based on the physical characteristics of the site or its immediate surroundings. In determining the use of location-specific ARARs for selection of remedial actions at CERCLA sites, the jurisdictional prerequisites of each regulation must be investigated. Basic definitions and exemptions are analyzed on a site-specific basis to confirm the correct applicability of the requirements. During the FS ARAR analysis, no location-specific ARARs were determined for Sites 37PS, 76CS, 76OD, and 126, only TBC guidance. Action-specific ARARs are technology-based requirements that set controls or restrictions on the design, implementation, and performance levels of remedial activities related to the management of hazardous substances, pollutants, or contaminants. These requirements are triggered by the remedial alternatives selected to clean up the hazardous wastes and are independent of specific chemicals at a site. Potential Federal and state action-specific ARARs for soil remedial actions are presented in Table 2-2 . Table 2-2. Potential Federal and State Action-specific ARARs Savanna Army Depot Activity, Savanna, Illinois
Applicable or Standard, Requirement, Relevant and Criteria, or Limitation Citation Description Appropriate RCRA 42 U.S.C Section 6901 et seq. Identification of Hazardous 40 CFR 261 Contains requirements for classification and Applicable Waste identification of hazardous wastes. Standards for Generators of 40 CFR 262 Establishes standards for the generators of Applicable Hazardous Waste hazardous wastes. Standards for 40 CFR 264 Subpart S – Special provisions for cleanup. Applicable Owners/Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities Land Disposal Restrictions 40 CFR 268 Subpart E – Prohibitions on storage, Applicable specifically 40 CFR 264.554 (staging piles). Illinois NPDES Permit 35 IAC 304 and 35 IAC 309 Establishes rules and procedures for the Relevant and Regulations administration of an NPDES permit system appropriate for the state. Phase II Stormwater Permit NOI, SWPP, NOT Stormwater permit for discharges associated Relevant and with construction activities. appropriate Visible and Particulate Matter 35 IAC 212 Standards and limitations for visible and Relevant and Emissions particulate matter emissions. appropriate Institutional Controls 35 IAC 742.1000, 35 IAC Institutional controls are required to restrict TBC 742.1010, 35 IAC 742.1012, access and prevent exposure to and Uniform Environmental contaminated media. These requirements Covenants Act are considered TBCs. Solid Waste and Special Waste 35 IAC 809 Identifies requirements for nonhazardous Applicable Hauling special waste hauling. Special Waste Decertification Sections 3.475 and 22.48, Contains requirements for decertification of Applicable Illinois Environmental any special waste generated at the sites. Protection Act Illinois Solid Waste 35 IAC 811 Special waste management. Applicable Management Regulations Subpart D
Savanna Army Depot, Final ROD 2-28 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
Considering the RAOs and site conditions and constraints, remedial alternatives were developed to address the COCs in soil at Sites 37PS, 76CS, 76OD, and 126. The Sites 24, 76CS, 99, and 126 FS (SAIC 2010a) identified and analyzed several possible remedial action alternatives that passed initial screening and were considered in detail in the FS. 2.11 DESCRIPTION OF ALTERNATIVES FOR SITES 37PS, 76CS, AND 76OD The human health risk assessment for Sites 37PS, 76CS, and 76OD identified arsenic, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, and dibenzo(a,h)anthracene as the COCs in soil (surface and subsurface) for the future industrial/commercial land use. To provide additional means for comparison, an unrestricted use alternative also was developed for evaluation. The proposed alternatives evaluated include: • Alternative 1: No Action • Alternative 2: Land Use Controls (LUCs) • Alternative 3: Excavation and Offsite Disposal with LUCs • Alternative 4: Excavation and Offsite Disposal (Unrestricted Use). Alternative 1: No Action Alternative—Evaluation of the no action alternative is required by CERCLA as a baseline to reflect current conditions without remediation. This alternative is used for comparison purposes only. Although natural processes (i.e., dispersion, absorption, or volatilization) may reduce contaminant concentrations over time, these processes would not be monitored. This alternative does not include any treatment, modeling, treatability studies, or LUCs. Alternative 2: LUCs—This alternative involves the use of administrative controls and engineering controls. The administrative controls are proposed to protect human receptors from contact with elevated concentrations of COCs in soil. The LUCs would focus on restricting future excavation, intrusive activities, and industrial activities. The administrative controls also will prohibit land development for residential use, elementary and secondary schools, child care facilities, playgrounds, or other occupancy uses that are tantamount to residential occupancy. Land use restrictions would be outlined in a LUC remedial design, with restrictions stated in full or by reference within deeds, easements, covenants, mortgages, leases, or other instruments of property transfer. The expected form of LUCs is a Uniform Environmental Covenant (UECA) for land to be transferred to the LRA. Restrictions would be maintained through all potential future property transfers. These controls would be drafted, implemented, and enforced in cooperation with state and local governments. Periodic monitoring of the site would be conducted annually and during the CERCLA 5-year reviews. Alternative 3: Excavation and Offsite Disposal with LUCs—This alternative involves excavation of soil containing COCs exceeding the PRGs for future industrial/commercial land use, transportation of the soil to a regulated landfill for disposal, site restoration, and implementation of LUCs. Confirmatory sampling would be performed in the excavation area to confirm that the residual concentrations within the excavation are below the industrial/construction PRGs. The proposed excavation areal extent of Alternative 3 is approximately 98,044 square feet. The vertical extent varies across the proposed excavation area; depths range from approximately 1 to 15 feet BLS. Clean backfill would be placed to restore the site. The railroad tracks within the site would require removal and replacement to accommodate site remediation. Since COCs would remain in soil at concentrations exceeding the residential PRGs, LUCs would be required to maintain the current industrial land use. The administrative controls will prohibit land development for residential use, elementary and secondary school, child care facilities, playgrounds, or other occupancy uses that are incompatible with industrial activity or are tantamount to residential occupancy. Periodic monitoring of the site following the soil removal would be conducted annually and during the CERCLA 5-year reviews. Proposed remedial activities at the site would be coordinated with SVDA personnel, including the railroad operator, to ensure minimal disruption to railroad operation.
Savanna Army Depot, Final ROD 2-29 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
This alternative will be referred to throughout the remainder of this ROD as Offsite Disposal with LUCs. Alternative 4: Excavation and Offsite Disposal (Unrestricted Use)—This alternative would consist of excavation of soils with COC concentrations above their respective residential PRGs followed by transportation and disposal at a permitted offsite facility. Confirmation sampling would be completed, the excavation backfilled using clean soil, and the site restored to the surrounding grade. The railroad tracks within the site would require removal and replacement to accommodate site remediation. As shown in Figure 2-2, the proposed excavation areal extent of Alternative 4 is approximately 104,243 square feet. The vertical extent varies across the proposed excavation area; depths range from approximately 1 to 15 feet BLS. LUCs would not be required because the site would meet the unrestricted (residential) use criteria at the completion of this alternative. Proposed remedial activities at the site would be coordinated with SVDA personnel, including the railroad operator, to ensure minimal disruption to railroad operation. This alternative will be referred to throughout the remainder of this ROD as Offsite Disposal for Unrestricted Use. 2.11.1 Comparative Analysis of Alternatives The comparative analysis of alternatives evaluated the performance of each alternative for Sites 37PS, 76CS, and 76OD relative to the specific evaluation criterion and the other alternatives. 2.11.1.1 Overall Protection of Human Health and the Environment The no action alternative does not include any actions and, consequently, is not expected to provide protection of human health and the environment by eliminating soil exposures to the current and future receptors. The LUCs Alternative (Alternative 2), Excavation and Offsite Disposal with LUCs alternative (Alternative 3), and Offsite Disposal alternative (Alternative 4) are considered protective of human health and the environment. For the LUCs alternative (Alternative 2), exposures would be eliminated by restricting excavation, intrusive activities, industrial activities, and prohibiting land development for residential use. For the Excavation and Offsite Disposal with LUCs alternative (Alternative 3), exposures would be eliminated by removing soil containing COCs exceeding the PRGs for future industrial/commercial land use and maintaining industrial land use to mitigate risks associated with exposure to COCs in soil associated with hypothetical residential use. Following the successful implementation of the Offsite Disposal alternative (Alternative 4), exposures would be eliminated by removing soil associated with hypothetical residential land use and LUCs would not be required. 2.11.1.2 Compliance with Applicable or Relevant and Appropriate Requirements Each alternative, except the no action alternative, would be designed to meet the action-specific ARARs. No chemical-specific ARARs exist for soil, only TBC guidance. No location-specific ARARs exist for Sites 37PS, 76CS, and 76OD, only TBC guidance. The action-specific ARARs are presented in Table 2-2 and discussed below. The Offsite Disposal alternatives and the LUCs alternative would comply with action-specific ARARs. Dust control requirements under 35 IAC 212 would be relevant and appropriate for the Offsite Disposal with LUCs and Offsite Disposal for Unrestricted Use alternatives. Construction activities associated with either Offsite Disposal activities would require compliance with the National Pollutant Discharge Elimination System (NPDES) for managing stormwater runoff. Requirements under 40 CFR 261 would be applicable for the identification of hazardous waste. Requirements under 40 CFR 262 through 264 and 268 would be applicable if the excavated soil is determined to be a hazardous waste. 40 CFR 264.554 would be applicable for the staging of excavated soil stockpiles if necessary.
Savanna Army Depot, Final ROD 2-30 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 D
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Arsenic Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Dibenzo(a,h)anthracene
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Land use restrictions would be implemented in accordance with UECA and 35 IAC 742.1000, 1010, and 1012 to prevent exposure to the contaminated soil. 2.11.1.3 Long-Term Effectiveness and Permanence The Offsite Disposal for Unrestricted Use alternative provides long-term effectiveness and permanence at Sites 37PS, 76CS, and 76OD because the contaminated soil would be excavated and removed. At the completion of this alternative, the remaining soil would be below residential PRGs. The Offsite Disposal with LUCs alternative provides long-term effectiveness and permanence by removing the contaminated soil exceeding the industrial/construction PRGs and maintaining the future industrial use at the sites. LUCs alternative would be effective in preventing exposure to the contaminated soil through administrative and engineering controls. The long-term effectiveness and permanence of the LUCs would depend on periodic monitoring and inspections of the controls. Although pathways to the contaminated soil are reduced under the LUCs alternative, the magnitude of the residual risk does not change because the contaminated soil remains at the site. The no action alternative does not provide long-term effectiveness and permanence. There would be no reduction in the potential for contaminant exposure because no remedial action would be implemented, and there is no concern about the adequacy and reliability of controls because none would be applied. 2.11.1.4 Reduction of Toxicity, Mobility, or Volume Through Treatment The no action and LUCs alternatives for Sites 37PS, 76CS, and 76OD do not include any treatment of contaminants as part of the alternative. Neither alternative would reduce toxicity, mobility, or volume of the soil COCs. In addition, no reduction in toxicity, mobility, or volume would occur from the implementation of the Offsite Disposal alternatives because soil would be disposed of in an offsite landfill without treatment. 2.11.1.5 Short-Term Effectiveness Both the no action and LUCs alternatives for Sites 37PS, 76CS, and 76OD present no additional risk to the community, environment, or site workers during its implementation because no active remedial actions are associated with these alternatives. The Offsite Disposal alternatives would present a modest risk to the community due to the transportation of contaminated soil on public roads. Proper soil handling techniques would be implemented to minimize adverse environmental impacts. Risks to site workers, the community, and the environment would be mitigated by practices documented in a Health and Safety Plan (HASP). 2.11.1.6 Implementability Because it requires no remedial actions, the no action alternative for Sites 37PS, 76CS, and 76OD would be the easiest to implement; however, as stated, it would not accomplish the remedial objectives. Services required for the LUCs are readily available and can be implemented with little effort. This alternative would require long-term annual inspections and 5-year reviews. The Offsite Disposal alternatives (Alternatives 3 and 4) would require modest level of effort for implementation. Equipment required for the Offsite Disposal alternatives is readily available. The alternatives have commonly been used and implemented successfully at SVDA during previous soil removal activities. The implementation of Alternative 4 would require excavating larger volumes of soil but does not require the long-term annual inspections and 5-year reviews required under Alternative 3.
Savanna Army Depot, Final ROD 2-32 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
2.11.1.7 Cost Table 2-3 presents a comparative summary of costs and remediation timeframes for the alternatives evaluated for soil at Sites 37PS, 76CS, and 76OD. Table 2-3. Sites 37PS, 76CS, and 76OD Comparative Summary of Costs and Remediation Timeframe Savanna Army Depot Activity, Savanna, Illinois
Total Remediation Timeframe Remedial Alternative Cost (years) 1. No Action $0 0 2. LUCs $588,894* 32 3. Offsite Disposal with LUCs $1,439,943* 32 4. Offsite Disposal for Unrestricted Use $1,457,321 3 *The costs presented for LUCs assumes design, implementation, and enforcement of the LUCs for Sites 37PS, 76CS, and 76OD will occur independently of other sites. Combining efforts to design, implement, and monitor LUCs Installation-wide will result in significant reduction in costs. As shown in Table 2-3, the LUCs alternative has the lowest estimated cost, except for the no action alternative, which has no cost. The costs estimated for Offsite Disposal with LUCs and Offsite Disposal for Unrestricted Use were comparable. However, Offsite Disposal for Unrestricted Use is expected to provide the added benefit of returning the site to unrestricted use in the shortest possible timeframe. The total cost (present worth) includes the capital costs for design and implementation of the remedy, operation and maintenance (O&M) cost, long-term monitoring cost, and site close-out documentation. For cost estimating purposes, the LUC costs will incur for a time period of 32 years. It may be determined during a CERLA 5-year review to reduce or extend the restrictions beyond the timeframe. Costing data and details are provided in Section 8 of the FS (SAIC 2010a). 2.11.1.8 Regulatory Acceptance USEPA Region 5 and IEPA provided review comments to the Proposed Plan (SAIC 2012) for Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 and concurred with the Army’s responses and the actions presented in the plan. 2.11.1.9 Community Acceptance Comments were received from the public to the Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 Proposed Plan during the month-long comment period between November 14, 2012 and December 14, 2012 and at the public meeting at SVDA in December 6, 2012. The Army has provided responses to these comments verbally during the public meeting and in writing following the public meeting. No further questions or comments have been received from the public and community acceptance of the selected remedy described in the Proposed Plan is inferred. 2.11.2 Principal Threat Waste The principal threat waste concept is applied to the characterization of source materials at a Superfund site. A source material includes or contains hazardous substances, pollutants, or contaminants that act as a reservoir for migration of contamination to groundwater, surface water, or air, or acts as a source for direct exposure. Contaminated groundwater generally is not considered to be a source material. Principal threat wastes are those source materials considered to be highly toxic or highly mobile that generally cannot be reliably contained, or would present a significant risk to human health or the environment should exposure occur.
Savanna Army Depot, Final ROD 2-33 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
Contaminated soil at Sites 37PS, 76CS, and 76OD is currently in place; therefore, the sites do contain principal threat source materials that pose risks at the high end of the target risk range (1 × 10-4 to 1 × 10-6) for future industrial land use (most likely land use) and exceeds the target risk range for hypothetical future residential use (most conservative risk assumptions). The source materials will be excavated and removed for offsite disposal at a permitted facility. 2.11.3 Selected Remedy The detailed analysis of alternatives and a comparative analysis to determine the advantages or disadvantages of the alternatives with respect to each other (SAIC 2009a) indicates that Alternative 4 – Excavation and Offsite Disposal for Unrestricted Use is recommended for implementation at Sites 37PS, 76CS, and 76OD. This alternative is selected because it meets the threshold criteria, is technically and administratively feasible. The soil excavation and offsite disposal would be completed in less than 1 year. This alternative would permanently remove the contaminated soil with concentrations above the residential PRGs from the site. There would be short-term risks to site workers and the community because of the soil excavation and transportation activities. The short-term risks would be mitigated through the use of best management practices (BMPs) and proper health and safety procedures. Implementation of this remedial alternative would result in conditions at the site that are suitable for the future unrestricted use of the site and implementation of LUCs, annual inspections, and 5-year reviews will not be required. The estimated costs for implementation of Alternative 4 are provided in Table 2-4. Table 2-4. Sites 37PS, 76CS, and 76OD Summary Cost Estimate for Alternative 4: Excavation and Offsite Disposal for Unrestricted Use Savanna Army Depot Activity, Savanna, Illinois
Phase Name Year 1 Year 2 Year 3 Total Remedial Design $101,444 — — $101,444 Remedial Action Excavation and Offsite Disposal — 1,392,486 — 1,392,486 Site Closeout — — $12,274 $12,274
Total Cost $101,444 1,392,486 $12,274 $1,506,204
Present Worth Cost $101,444 $1,355,877 $11,637 $1,457,321 Note: Present Worth Cost was calculated based on a 2.7 percent discount rate. "—" Cost Not Applicable
2.12 DESCRIPTION OF ALTERNATIVES FOR SITE 126 The human health risk assessment for Site 126 identified benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, and indeno(1,2,3-cd)pyrene as the COCs in soil (surface and subsurface) for the future industrial land use. An unrestricted use alternative also was developed for evaluation. The proposed alternatives evaluated include: Alternative 1: No Action Alternative 2: LUCs Alternative 3: Excavation and Offsite Disposal with LUCs Alternative 4: Excavation and Offsite Disposal (Unrestricted Use). Alternative 1: No Action—Evaluation of the no action alternative is required by CERCLA as a baseline to reflect current conditions without remediation. This alternative is used for comparison purposes only. Although natural processes (i.e., dispersion, absorption, or volatilization) may reduce
Savanna Army Depot, Final ROD 2-34 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
contaminant concentrations over time, these processes would not be monitored. This alternative does not include any treatment, modeling, treatability studies, or LUCs. Alternative 2: LUCs—This alternative involves the implementation of administrative controls and engineering controls. The administrative controls are proposed to protect human receptors from contact with elevated concentrations of the COCs in soil. The LUCs would focus on restricting future excavation, intrusive activities, and industrial activities. The administrative controls will prohibit land development for residential use, elementary and secondary school, child care facilities, playgrounds, or other occupancy uses that are tantamount to residential occupancy. Land use restrictions would be outlined in a LUC remedial design, with restrictions stated in full or by reference within deeds, easements, covenants, mortgages, leases, or other instruments of property transfer. The expected form of LUCs is a UECA for land to be transferred to the LRA. Restrictions would be maintained through all potential future property transfers. These controls would be drafted, implemented, and enforced in cooperation with state and local governments. Periodic monitoring of the site would be conducted annually and during the CERCLA 5-year reviews. Alternative 3: Excavation and Offsite Disposal with LUCs—This alternative involves excavation of soil containing COCs exceeding the PRGs for future industrial/commercial land use, transportation of the soil to a regulated landfill for disposal, site restoration, and implementation of LUCs. Confirmatory sampling would be performed in the excavation area to confirm that the residual concentrations within the excavation are below the industrial/construction PRGs. Clean backfill would be placed to restore the site. The proposed excavation areal extent of Alternative 3 is approximately 5,075 square feet. The vertical extent varies across the proposed excavation area; depths range from approximately 1 to 15 feet BLS. Since COCs would remain in soil at concentrations exceeding the residential PRGs, LUCs would be required to maintain industrial use of the property. The administrative controls will prohibit land development for residential use, elementary and secondary schools, child care facilities, playgrounds, or other occupancy uses that are incompatible with industrial activity or are tantamount to residential occupancy. Periodic monitoring of the site following the soil removal would be conducted annually and during the CERCLA 5-year review. This alternative will be referred to throughout the remainder of this Proposed Plan as Offsite Disposal with LUCs. Alternative 4: Excavation and Offsite Disposal (Unrestricted Use)—This alternative would consist of excavation of soils with COC concentrations above the residential PRG followed by transportation and disposal at a permitted offsite facility. Confirmation sampling would be completed, the excavation backfilled using clean soil, and the site restored to the surrounding grade. As shown on Figure 2-3, the proposed excavation areal extent of Alternative 4 is approximately 6,442 square feet. The vertical extent varies across the proposed excavation area; depths range from approximately 1 to 15 feet BLS. This alternative will be referred to throughout the remainder of this Proposed Plan as Offsite Disposal for Unrestricted Use. 2.12.1 Comparative Analysis of Alternatives The comparative analysis of alternatives (SAIC 2010a) evaluated the performance of each alternative for Site 126 relative to the specific evaluation criterion and the other alternatives. 2.12.1.1 Overall Protection of Human Health and the Environment The no action alternative does not include any actions and, consequently, is not expected to provide protection of human health and the environment by eliminating soil exposures to the current and future receptors. The LUCs Alternative (Alternative 2), Excavation and Offsite Disposal with LUCs alternative (Alternative 3), and Offsite Disposal alternative (Alternative 4) are considered protective of human health
Savanna Army Depot, Final ROD 2-35 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 95 Feet Feet 50 50
25 25 DATE:1/24/2013
q 0 SITE SITE 126 NOT TO SCALE 0 NOT TO SCALE K E Y M A P K E Y M A P 12.5 12.5 SAVANNA,ILLINOIS 25 25 SITE SAVANNA ARMY DEPOTACTIVITY PROPOSED EXCAVATIONLIMITS FIGURE: 2-3 SOIL BORING EXCEEDING FUTURE RESIDENTIAL PRGs SOIL BORING RAILROAD ROADS EXISTING UST ABANDONED STORAGE TANK BUILDINGS SITE 126 PROPOSED SUBSURFACE EXCAVATIONAREA PROPOSED SURFACE EXCAVATIONAREA LOCATION " " PROJECT:\GIS_DATA\SVAD\Projects\Sites_24_76CS_99_126\ 10 Sites ROD\Figure 2-3 126Site Excavation Limits.mxd E E Legend 501 Chemicals of Concern of Chemicals
Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Dibenzo(a,h)anthracene Indeno(1,2,0-cd)pyrene
511 CN Loop CN 502 Medium of Concern of Medium Soil SB-126-06 SB-126-05 SB-126-02 "" SB-126-08 EE "" EE "" EE "" 503 EE SB-126-01 " "" E EE " "" E EE " E SB-126-09 SB-126-07 SB-126-03
CNLoop
SB-126-04 CN Service Road Service CN 504
Savanna Army Depot, Final ROD 2-36 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
and the environment. For the LUCs alternative (Alternative 2), exposures would be eliminated by restricting excavation, intrusive activities, industrial activities, and prohibiting land development for residential use. For the Excavation and Offsite Disposal with LUCs alternative (Alternative 3), exposures would be eliminated by removing soil containing COCs exceeding the PRGs for future industrial/commercial land use and maintaining industrial land use to mitigate risks associated with exposure to COCs in soil associated with hypothetical residential use. Following the successful implementation of the Offsite Disposal alternative (Alternative 4), exposures would be eliminated by removing soil associated with hypothetical residential land use and LUCs would not be required. 2.12.1.2 Compliance with Applicable or Relevant and Appropriate Requirements Each alternative, except the No Action alternative, would be designed to meet the action-specific ARARs. No chemical-specific ARARs exist for soil, only TBC guidance. No location-specific ARARs exist for Site 126, only TBC guidance. The action-specific ARARs are presented in Table 2-2 and discussed below. The Offsite Disposal alternatives and the LUCs alternative would comply with action-specific ARARs. Dust control requirements under 35 IAC 212 would be relevant and appropriate for the Offsite Disposal with LUCs and Offsite Disposal for Unrestricted Use alternatives. Construction activities associated with either Offsite Disposal activities would require compliance with NPDES for managing stormwater runoff. Requirements under 40 CFR 261 would be applicable for the identification of hazardous waste. Requirements under 40 CFR 262 through 264 and 268 would be applicable if the excavated soil is determined to be a hazardous waste. 40 CFR 264.554 would be applicable for the staging of excavated soil stockpiles if necessary. Land use restrictions would be implemented in accordance with UECA and 35 IAC 742.1000, 1010, and 1012 to prevent exposure to the contaminated soil. 2.12.1.3 Long-Term Effectiveness and Permanence The Offsite Disposal for Unrestricted Use provides long-term effectiveness and permanence at Site 126 because the contaminated soil would be excavated and removed. At the completion of this alternative, the remaining soil would be below the residential PRG. The Offsite Disposal with LUCs alternative provides long-term effectiveness and permanence by removing the contaminated soils exceeding the industrial/construction PRGs and maintaining the future industrial use at the site. The LUCs alternative would be effective in preventing exposure to the contaminated soil through administrative and engineering controls. The long-term effectiveness and permanence of the LUCs would depend on periodic monitoring and inspections of the controls. Although pathways to the contaminated soil are reduced under the LUCs alternative, the magnitude of the residual risk does not change because the contaminated soil remains at the site. The no action alternative does not provide long-term effectiveness and permanence. There would be no reduction in the potential for contaminant exposure because no remedial action would be implemented, and there is no concern about the adequacy and reliability of controls because none would be applied. 2.12.1.4 Reduction of Toxicity, Mobility, or Volume Through Treatment The no action and the LUCs alternatives for Site 126 do not include any treatment of contaminants as part of the alternative. Neither alternative would reduce toxicity, mobility, or volume of the soil COCs. In addition, no reduction in toxicity, mobility, or volume would occur from the implementation of the Offsite Disposal alternatives because soil would be disposed of in an offsite landfill without treatment.
Savanna Army Depot, Final ROD 2-37 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
2.12.1.5 Short-Term Effectiveness Both the no action and the LUCs alternatives for Site 126 present no additional risk to the community, environment, or site workers during its implementation because no active remedial actions are associated with these alternatives. The Offsite Disposal alternatives would present a modest risk to the community due to the transportation of contaminated soil on public roads. Proper soil handling techniques would be implemented to minimize adverse environmental impacts. Risks to site workers, the community, and the environment would be mitigated by practices documented in a HASP. 2.12.1.6 Implementability Because it requires no remedial actions, the no action alternative for Site 126 would be the easiest to implement; however, as stated, it would not accomplish the remedial objectives. Services required for the LUCs are readily available and can be implemented with little effort. This alternative would require the long-term annual inspections and 5-year reviews. The offsite disposal alternatives (Alternatives 3 and 4) would require modest level of effort for implementation. Equipment required for the Offsite Disposal alternatives is readily available. The alternatives have commonly been used and implemented successfully at SVDA during previous soil removal activities. The implementation of Alternative 4 would require excavating larger volumes of soil but does not require the long-term annual inspections and 5-year reviews required under Alternative 3. 2.12.1.7 Cost Table 2-5 presents a comparative summary of costs and remediation timeframes for the alternatives evaluated for soil at Site 126. Table 2-5. Site 126 Comparative Summary of Costs and Remediation Timeframe Savanna Army Depot Activity, Savanna, Illinois Total Remediation Timeframe Remedial Alternative Cost (years) 1. No Action $0 0 2. LUCs $588,893* 32 3. Offsite Disposal with LUCs $652,409* 32 4. Offsite Disposal for Unrestricted Use $389,026 3 *The costs presented for LUCs assumes design, implementation, and enforcement of the LUCs for Site 126 will occur independently of other sites. Combining efforts to design, implement, and monitor LUCs Installation-wide will result in significant reduction in costs. As shown in Table 2-5, the Offsite Disposal for Unrestricted Use alternative has the lowest estimated cost, except for the no action alternative, which has no cost. The costs estimated for LUCs and Offsite Disposal with LUCs were comparable. The Offsite Disposal for Unrestricted Use alternative is expected to provide the added benefit of returning the site to unrestricted use in the shortest possible timeframe. The total cost (present worth) includes the capital costs for design and implementation of the remedy, O&M cost, long-term monitoring cost, and site close-out documentation. For cost estimating purposes, the LUC costs will incur for a time period of 32 years. It may be determined during a CERCLA 5-year review to reduce or extend the restrictions beyond the timeframe. Costing data and details are provided in Section 8 of the FS (SAIC 2010a). 2.12.1.8 Regulatory Acceptance USEPA Region 5 and IEPA provided review comments to the Proposed Plan (SAIC 2012) for Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 and concurred with the Army’s responses and the actions presented in the plan.
Savanna Army Depot, Final ROD 2-38 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
2.12.1.9 Community Acceptance Comments were received from the public to the Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 Proposed Plan during the month-long comment period between November 14, 2012 and December 14, 2012 and at the public meeting at SVDA in December 6, 2012. The Army has provided responses to these comments verbally during the public meeting and in writing following the public meeting. No further questions or comments have been received from the public and community acceptance of the selected remedy described in the Proposed Plan is inferred. 2.12.2 Principal Threat Waste The principal threat waste concept is applied to the characterization of source materials at a Superfund site. A source material includes or contains hazardous substances, pollutants, or contaminants that act as a reservoir for migration of contamination to groundwater, surface water, or air, or acts as a source for direct exposure. Contaminated groundwater generally is not considered to be a source material. Principal threat wastes are those source materials considered to be highly toxic or highly mobile that generally cannot be reliably contained, or would present a significant risk to human health or the environment should exposure occur. Contaminated soil at Site 126 is currently in place; therefore, the site does contain principal threat source materials that pose risks within the target risk range (1 × 10-4 to 1 × 10-6) for future industrial land use (most likely land use) or exceeds the target risk range for hypothetical future residential use (most conservative risk assumptions). The source materials will be excavated and removed for offsite disposal at a permitted facility. 2.12.3 Selected Remedy The detailed analysis of alternatives and a comparative analysis to determine the advantages or disadvantages of the alternatives with respect to each other (SAIC 2010a) indicates that Alternative 4 – Excavation and Offsite Disposal for Unrestricted Use is recommended for implementation at Site 126. This alternative is selected because it meets the threshold criteria, is technically and administratively feasible. The soil excavation and offsite disposal would be completed in less than 1 year. This alternative would permanently remove the contaminated soil with concentrations above the residential PRGs from the site. There would be short-term risks to site workers and the community because of the soil excavation and transportation activities. The short-term risks would be mitigated through the use of BMPs and proper health and safety procedures. Implementation of this remedial alternative would result in conditions at the site that are suitable for the future unrestricted use of the site, and the implementation of LUCs, annual inspections, and 5-year reviews will not be required. The estimated costs for implementation of Alternative 4 are provided in Table 2-6. Table 2-6. Site 126 Summary Cost Estimate for Alternative 4: Excavation and Offsite Disposal for Unrestricted Use Savanna Army Depot Activity, Savanna, Illinois Phase Name Year 1 Year 2 Year 3 Total Remedial Design $74,851 – – $74,851 Remedial Action Excavation and Offsite Disposal – $310,706 – $310,706 Site Closeout – – $12,274 $12,274 Total Cost $74,851 $310,706 $12,274 $397,831 Present Worth Cost $74,851 $302,537 $11,637 $389,026 Note: Present Worth Cost was calculated based on a 2.7 percent discount rate. "–" Cost Not Applicable
Savanna Army Depot, Final ROD 2-39 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
2.13 STATUTORY DETERMINATIONS The human health and ecological risk assessments concluded that no action is required for six sites (Sites 5, 24, 69, 155, 184, and 186). Remedial actions are required for four sites (Sites 37PS, 76CS, 76OD, and 126). RAOs were developed that are site-specific goals for protecting human health and the environment and specify the contaminants, media of interest, exposure pathways, and cleanup goals established from chemical-specific regulatory standards. The RAOs for soil at Sites 37PS, 76CS, 76OD, and 126 consider the industrial/construction and residential PRGs for the soil COCs. The COCs and the cleanup goals based on TACO Tier I Soil Remediation Objectives for industrial/commercial and residential properties (35 IAC 742, Appendix B) are presented in Table 2-7. Table 2-7. Cleanup Goals Savanna Army Depot Activity, Savanna, Illinois
Cleanup Goals Chemicals of Concern Industrial/Commerciala Residentiala Arsenic 11.3b mg/kg 11.3b mg/kg Benzo(a)anthracene 8,000 µg/kg 900 µg/kg Benzo(a)pyrene 800 µg/kg 90 µg/kg Benzo(b)fluoranthene 8,000 µg/kg 900 µg/kg Dibenzo(a,h)anthracene 800 µg/kg 90 µg/kg Indeno(1,2,3-cd)pyrene 8,000 µg/kg 900 µg/kg aThe industrial/commercial cleanup goals are the minimum required to achieve RAOs for Sites 37PS, 76CS, 76OD, and 126. However, the Army is proposing to clean up these sites to future unrestricted use by achieving the residential cleanup goals. bBackground value based on IEPA state background concentration for counties outside metropolitan statistical areas (35 IAC 742 Appendix A).
The selected remedy is protective of human health and the environment, complies with Federal and state requirements that are legally applicable or relevant and appropriate to the remedial action, and are cost-effective. The remedy utilizes a permanent solution to remove the contaminated soil from the site for disposal at a permitted offsite facility. The selected remedy, however, does not satisfy the statutory preference for remedies that employ treatment to reduce toxicity, mobility, or volume as a principal element. Potential treatment technologies were considered in the FS detailed screening process but were not retained because of effectiveness and implementability concerns, and the medium to high cost of treatment. Excavation and offsite disposal were determined to be the cost-effective approach for these sites based on the volume of soil requiring remediation and availability of permitted disposal facilities within a reasonable distance from SVDA. 2.14 DOCUMENTATION OF SIGNIFICANT CHANGES The Proposed Plan for Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 was released for public comment in November 2012 (SAIC 2012). No action was recommended for six sites (Sites 5, 24, 69, 155, 184, and 186) in the Proposed Plan. The Proposed Plan recommended Excavation and Offsite Disposal of soil to attain Unrestricted Land Use at four sites (Sites 37PS, 76CS, 76OD, and 126). A public meeting was held at SVDA on December 6, 2012. Army, USEPA, and IEPA representatives were present at the public meeting and answered questions received from the public. There were written comments received during the public comment period and verbal comments were received at the public meeting. The Army reviewed all of the comments and it was determined that no significant changes to the remedy, as originally identified in the Proposed Plan, were necessary or appropriate.
Savanna Army Depot, Final ROD 2-40 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
3. RESPONSIVENESS SUMMARY The following responsiveness summary provides information about the general comments received during the public comment period. Specific parts of the responsiveness summary include the overview and summary of comments received during the public comment period. 3.1 BACKGROUND ON COMMUNITY INVOLVEMENT Community involvement with the remedy selection process for the 10 sites started with the invitation to attend a public meeting held on December 6, 2012. Three members of the community attended the public meeting and provided verbal comments. In addition, written comments were submitted by the community during the public comment period. Community relations activities conducted for the 10 sites have included the following: • The Army placed the EBS Report in the information repository (IR) (May 1999) • The Army placed the Lower Post RI Report in the IR (October 2004) • The Army placed the RI Report for the CL and CN Plant Areas and Remaining LRA Parcels in the IR (April 2007) • The Army placed the RI Report for Sites 46, 76CS, 84, and 184 in the IR (June 2007) • The Army placed the RI Report for the CF Plant Area in the IR (August 2007) • The Army placed the RI Report for the Upper Post Area in the IR (April 2009) • The Army placed the Supplemental Groundwater Investigation at the CF Plant Melt and Pour Facility (Site 24) in the IR (December 2009) • The Army placed the Sites 5, 69, and 184 FFS in the IR (April 2010) • The Army placed the Sites 24, 76CS, and 126 FS in the IR (July 2010) • The Army prepared and distributed the Proposed Plan for Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 (November 2012) • The Army issued multiple public notices in five area newspapers notifying the citizens of the public meeting and public comment period (November and December 2012) • The Army held a public meeting (December 2012) at SVDA to describe the Proposed Plan and respond to citizen questions. 3.2 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD The public comment period on the Proposed Plan for Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186 was held from November 14 to December 14, 2012. Comments and questions were received during the December 6, 2012 public meeting. Comments resolved during the meeting and comments that required follow-up responses are summarized in the following sections. Comments provided in writing by one commenter with responses also are summarized below. A copy of the meeting transcript and the original comment letter received are provided in Appendix C. The following sections present and address stakeholder comments. 3.2.1 Public Meeting Comments and Resolution The following comments were received during the December 6, 2012 public meeting and were addressed at that time.
Savanna Army Depot, Final ROD 3-1 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
• Comment: During the human health risk assessment, there did not appear to be a recreational component associated with hunting and the associated human consumption of wild game. Were there any samples collected and analyzed relative to larger game, such as deer? Response: Large wild game was not expressly analyzed during the human health risk assessment for these sites. However, consumption of deer meat was evaluated at the TNT Washout Lagoons in 1992-1993. This study indicated that TNT was not a concern for human health through the ingestion of deer meat. This study is considered a baseline for the facility. Based on this information, since TNT was not a concern at the TNT Washout Lagoon, it is not expected to be a concern at the 10 sites presented in this ROD. • Comment: The existing footprint that is associated with Riverport Railroad that will require remediation appears to be what the railroad company has understood it to be. What is the next step following the public comment period? Where do we go from here? Response: The next step is to document everything that has been pulled together and document the decisions in a ROD, which is the CERCLA decision point. The next step is doing a remedial design followed by cleanup at the site. Following confirmation sampling and a construction completion report, stating the cleanup goals have been met, the site will be formally closed. • Comment: At Site 126 and other sites, coal is identified as a contaminant. Is there a risk for workers running our railroad locomotives over the railroad tracks on this property as risk from coal contamination? Should the railroad workers be wearing masks at these sites? Response: The risk at Site 76CS was conservatively evaluated using a scenario in which a worker is onsite for 8 hours a day, 250 days a year, for 25 years. This evaluation indicated there are unacceptable risks for the future industrial and commercial land uses. After implementation of the Offsite Disposal for Unrestricted Land Use alternative, the site will be protective of future land users, such as railroad workers. Wearing masks will not be necessary. 3.2.2 Public Meeting Comments and Follow-up Resolution The following comments were received during the December 6, 2012 public meeting and required responses outside of the public meeting time regarding ecological concerns at Sites 5 and 184. • Comment: At Site 5, lead, zinc, and carbon tetrachloride were detected. SAIC concluded the detections weren’t an ecological concern due to the small area of the site. Aren’t these detections bad for wildlife? Response: Although soil samples were analyzed for carbon tetrachloride, carbon tetrachloride was not detected in any soil sample at the site or at a nearby site (Site 100). Carbon tetrachloride was detected in groundwater; however, the aquifer is approximately 46.5 feet BLS. Wildlife is unlikely to contact groundwater below the land surface and there are no springs or seeps at the site or the vicinity where groundwater may be discharged. Therefore, exposure of ecological receptors to contaminants in groundwater is considered an incomplete pathway and wildlife at the site are not exposed to carbon tetrachloride. Ecological risks at Site 5 were evaluated through food-chain modeling using conservative exposure and toxicity assumptions. These risks were estimated using the maximum detected concentrations of lead (115 mg/kg) and zinc (283 mg/kg). Although the small acreage associated with Site 5 (0.3 acres) was considered in the recommendation for no further action for the site in the form of a baseline ecological risk assessment (a more realistic ecological risk
Savanna Army Depot, Final ROD 3-2 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
evaluation), the potential effects of the average concentrations of lead and zinc on populations of wildlife also were considered. The average concentrations of lead and zinc in the surface soil were 73.8 and 155 mg/kg, respectively. These average concentrations are below or the same order of magnitude as their conservative ecological screening values (85 mg/kg for lead and 140 mg/kg for zinc). The metal concentrations at the site do not warrant further action to protect populations of wildlife. • Comment: Site 184 is less than 0.018 acres and mercury and other metals were detected in the surface soil with potential for adverse effects to ecological receptors. Why is Site 184 recommended for no further action (NFA), particularly with the presence of mercury there? Response: At Site 184, surface and shallow subsurface samples were collected at the base of an excavation after a deteriorating drum used to collect compressor effluent and associated stained soil on the north side of Building 640 were removed. The potential risks for wildlife from mercury and other metals are discussed below. Mercury is a naturally occurring element found in soil. Mercury was detected at Site 184 in one of six surface soil samples at a concentration of 0.045 mg/kg. Mercury was not detected in the subsurface soil samples collected at the site. In comparison to background soil (soil collected from areas that have not been impacted by contamination), the detected concentration at Site 184 was less than the detected concentration in background soil (0.11 mg/kg). As a result, the concentration of mercury at Site 184 is considered naturally occurring. Because mercury has persistent, bioaccumulative, and toxic properties, risks from mercury were evaluated for wildlife through food-chain modeling even when the site concentrations are considered naturally occurring. None of the hazard quotients (HQs) associated with mercury was above the conservative screening value of 1. Therefore, the mercury concentration at Site 184 does not warrant further action. The potential risks for wildlife associated with surface soil concentrations of antimony, copper, lead, selenium, and zinc also were evaluated through food-chain modeling. All but one of the HQs were below 1 with the incorporation of more realistic exposure assumptions (i.e., consideration of the site acreage, varied diets, and arithmetic mean concentrations as exposure point concentrations). The HQ for robins from lead was 2.3. The maximum detected concentrations of lead were at the base of the excavated soil immediately north of Building 640. Lead concentrations in the surrounding samples 4 to 6 feet west, north, and east of the excavated soil area had significantly lower lead concentrations ranging from 54.8 to 97.4 mg/kg. These concentrations are within the range of lead concentrations detected in background soils (ranging from 3.6 to 106 mg/kg) and are considered naturally occurring. Building 640 bounds the excavated area to the south. Wildlife exposures to the elevated concentrations of lead at the base of the excavated soil area in close proximity to Building 640 would be limited spatially. As a result, no further action is warranted at this site. • Comment: Given that Site 184 is such a small area, why couldn’t another 2 inches of soil be removed and disposed of off-site to remove any residual risks and uncertainty associated with mercury and the other metals? Response: The mercury concentration at Site 184 is naturally occurring and additional soil removal would not benefit the wildlife at the site. Although HQs were present at Site 184 for robins from lead, even with some more realistic exposure assumptions incorporated, the magnitude of the HQ (HQ of 2.3), the limited area associated with elevated concentrations, and the conservative assumptions in the ecological risk assessment were considered in determining that no further action in the form of a baseline ecological risk assessment (a more realistic ecological risk evaluation) or a feasibility study considering removal actions were
Savanna Army Depot, Final ROD 3-3 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
required for the site to protect populations of wildlife. As a result of following the CERCLA process, it was determined that no further action was required at Site 184. 3.2.3 Written Comments Written comments were received from one participant. The following questions were posed with respect to evaluation of groundwater in the human health risk assessments, a lack of clarity with the remedial actions associated with a preferred remedy, and clarification on the proposed boundaries for excavation areas associated with Sites 37CS, 76CS, and 76OD: • Comment: Page 29, Paragraph 3 under Human Health Risk Assessment Results: Potential groundwater use is not considered relevant at this site, and some others, but seems to be of possible importance at other sites. (Comments on groundwater on Sites 5 and 24 indicate that groundwater was considered relevant to future land use on this site, and water quality was assessed.) Response: Groundwater at each site is evaluated in a tiered fashion. Initially, the site history and contamination in the soil are examined. Concentration by depth is examined (e.g., do concentrations decrease or disappear at depth), and the specific chemicals and their potential to migrate are evaluated. Based on this information, groundwater samples are collected where site history and soil data indicate potential groundwater contamination. A Hydropunch® groundwater sample is typically collected first. If this sample shows potential contamination, a monitoring well is installed and groundwater samples are collected from the monitoring well (samples collected from a developed monitoring well are more accurate than Hydropunch® samples and considered to have sufficient data quality to support risk assessment).
At Sites 37PS, 69, 76CS, 76OD, 126, and 186, Hydropunch® groundwater samples were collected, but the sample results did not warrant further groundwater investigation. At Sites 5, 24, and 155, groundwater samples from monitoring wells were collected and risks for residents exposed to the groundwater were calculated. The risk assessment of the groundwater resulted in acceptable risks for residential land use. At Site 184, neither Hydropunch® nor monitoring well groundwater samples were collected based on soil data collected. • Comment: Page 30 under Preferred Remedy (Site 69): Soils were apparently assessed, but not groundwater. With the possibility of the present water system not being used in the future, there may be a need for the future land users to sink wells for their use, whether industrial or residential? Response: As stated above, the risk assessment indicates groundwater concentrations are within acceptable risk limits for residential land use. Since the assessment of residential land use is more conservative than the assessment of industrial and commercial land use, it is concluded that groundwater concentrations are also within acceptable risk limits for use by future industrial and commercial workers. • Comment: Preferred Remedy Statements on various sites: As this is the final proposed plan, in the interest of clarity, it would seem that the Preferred Remedy would contain an actual reference to the preferred remedy, not i.e. “Evaluation of Site 126 indicated that risks posed by chemicals detected at the site are considered unacceptable to humans. Therefore, based on these results, further remedial action or land use restriction is required.” With no reference to the remedial action being recommended? Response: The comment is valid. As this is a final document, no change will be made to this Proposed Plan. However, future documents will reference the remedial action being recommended under the Preferred Remedy section.
Savanna Army Depot, Final ROD 3-4 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
• Comment: Regarding Sites 37PS, 76CS, and 76OD: If I understand the map of the proposed excavation, the blue x’s show borings with excess contamination and red x’s show borings without excess contamination. If this is the only measurement, especially along the east side of the proposed excavation, why is there only one soil boring showing no excess contamination? If would seem that to find the boundaries of the contamination, that there would be more borings needed, unless I am missing some other method that was used to find the boundaries? Response: The proposed excavation area for Sites 37PS, 76CS, and 76OD is based on residential cleanup objectives and the extent of the excavation area presented in the Proposed Plan was determined as follows: – The lateral extent of excavation was defined by half the distance between a sample with concentrations above the cleanup objective and an adjacent sample below the cleanup objective. – Or, if no adjacent sample is available (as is the case with much of the eastern side of the proposed excavation), the lateral extent is assumed to be 15 feet from the sample above the cleanup objective.
During excavation activities, confirmatory samples would be collected in the excavation area (i.e., the floor and sidewalls) to ensure that the extent of soil exceeding residential cleanup goals is removed from the site.
Savanna Army Depot, Final ROD 3-5 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
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4. REFERENCES CAPE (Cape Environmental Management, Inc.). 2006. Construction Completion Report for Remedial Action Environmental Restoration at the Ammunition Peculiar Equipment (APE) Shop Rear Dock (Site 76AD), Nitric Acid Storage Area (Site 44), and CF Plant (Site 25). Final. Savanna Army Depot Activity, Savanna, Illinois. September. Churchwell, S. and T. Biasi. 1995. APE Fabrication Branch Employees, SVDA. Personal Interview. October. Clarke, J. 1995. BRAC Environmental Coordinator, SVDA. Personal Communication. January-April. Clarke, J. 1996. BRAC Environmental Coordinator, SVDA. Personal Communication. January- April. DA (Department of the Army). 1989. U.S. Environmental Protection Agency, Region V; the State of Illinois; and the United States Army, Federal Facility Agreement Under CERCLA Section 120. September 26. Dames & Moore. 1994. Preliminary Draft Remedial Investigation Report, Savanna Army Depot Activity, Savanna, Illinois. Prepared for the U.S. Army Environmental Center. June. Dames & Moore. 1995. Removal Site Evaluation and Engineering Evaluation and Cost Analysis for the CF and CL Areas. Final. Savanna Army Depot Activity, Savanna, Illinois. April. ESE (Environmental Science and Engineering, Inc.). 1982. Rapid Response Environmental Surveys, Savanna Army Depot Activity, Final Report. Prepared for Savanna Army Depot Activity, Savanna, Illinois, and the U.S. Army Toxic and Hazardous Materials Agency. March. Hunter/ESE. 1989. Environmental Monitoring, Savanna Army Depot Activity, Technical Report. Prepared for U.S. Army Toxic and Hazardous Materials Agency. June. IEPA (Illinois Environmental Protection Agency). 1997. Letter from Charlene Falco, Remedial Project Manager, IEPA, to John Clarke, BRAC Environmental Coordinator, SVDA, providing comments on supporting documentation for Underground Storage Tanks. Submitted by SAIC. May 15. IEPA. 2001. Groundwater Quality Standards for Class I: Potable Resource Groundwater. Title 35 of the Illinois Administrative Code, Subtitle F: Public Water Supplies, Chapter I: Pollution Control Board, Part 6209: Groundwater Quality, Section 620.410. IEPA (Illinois Environmental Protection Agency). 2002. Tiered Approach to Corrective Action Objectives. Title 35: Environmental Protection, Subtitle G: Waste Disposal, Chapter I: Pollution Control Board, Subchapter f: Risk Based Cleanup Objectives, Part 742. ERA (Economics Research Associates). 1997. Savanna Army Depot Reuse Plan and Implementation Strategy. Prepared for the Savanna Army Depot LRA. January MSA (MSA Professional Services). 2005. Reuse Plan Update for Eagle’s Landing Development (Formerly the Savanna Army Depot). May. Q.C. Metallurgical Laboratory, Inc. 1995. Collection and Analysis of Soil Samples from an Ammunition Storage Site. July 21. Robinson, W. 1996. Mission Division Chief, SVDA. Personal Communications. January, April, and May. SAD (Savanna Army Depot). 1966. Provide Protection Facilities for Modification of 90 MM Cartridges Plan, Buildings 729 and 776. Depot Facilities Division. January 19. SAIC (Science Applications International Corporation). 1999. Environmental Baseline Survey Report. Savanna Army Depot Activity, Savanna, Illinois. Final. May.
Savanna Army Depot, Final ROD 4-1 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
SAIC. 2004. Lower Post Remedial Investigation, Savanna Army Depot Activity, Savanna, Illinois. Final. October. SAIC. 2007a. Remedial Investigation Report for CF Plant Area, Savanna Army Depot Activity, Savanna, Illinois. Final. August. SAIC. 2007b. Remedial Investigation Report for the CL and CN Plant Areas and Remaining LRA Parcels, Savanna Army Depot Activity, Savanna, Illinois. Final. April. SAIC. 2007c. Remedial Investigation Report for Sites 46, 76CS, 84, and 184, Savanna Army Depot Activity, Savanna, Illinois. Final. June. SAIC. 2009a. Supplemental Groundwater Investigation at the CF Plant Melt and Pour Facility (Site 24) and the Building 762 CF Plant Battery Shop (Site 99), Savanna Army Depot Activity, Savanna, Illinois. Final. December. SAIC. 2009b. Remedial Investigation Report for the Upper Post Area. Savanna Army Depot Activity, Savanna, Illinois. Final. April. SAIC. 2010a. Sites 24, 76CS, 99, and 126 Feasibility Study, Savanna Army Depot Activity, Savanna, Illinois. Final. July. SAIC. 2010b. Sites 5, 69, and 184 Focused Feasibility Study, Savanna Army Depot Activity, Savanna, Illinois. Final. Prepared for the U.S. Army Corps of Engineers. April. SAIC. 2012. Proposed Plan Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186, Savanna Army Depot Activity, Savanna, Illinois. Final. November. Sheehy, M. 1995. Machinist Foreman, SVDA. Personal Interview. October. Sheehy, M. 1997. Machinist Foreman, SVDA. Personal Communication during Visual Inspection. May. SOD (Savanna Ordnance Depot). 1941. Standard Boostering Building. Vacuum Line Details. Ordnance Department. July 1940, revised January 15, 1941. SOD. 1953a. Historical Report, January through June 1953. SOD. 1953b. Historical Report, July through December 1953. SOD. 1955. Historical Report, July through December 1955. SOD. 1973. Unit Maps Construction Program 1938 to 1943. Sheet No. 24, U.S. Engineer Area Office. November 1, 1944 revised through November 27, 1973. Straight. L. 1998. Civil Engineer, SVDA. Personal communications. February through March. SVDA (Savanna Army Depot Activity). 1979. The Master Plan of Savanna Army Depot Activity, Illinois, Building Information Schedule. April. SVDA. 1985. Stationary Air Pollution Source Assessment, Contaminated Waste Processor, Savanna Army Depot Activity, Savanna, Illinois. June 3-7. SVDA. 1992. Waste Management Plan for Savanna Army Depot Activity, Savanna, Illinois SVDA. 1993a. Permit Application for Hazardous Waste Facilities at Savanna Army Depot Activity, Savanna, Illinois. Prepared for the U.S. Army Environmental Center by Haliburton NUS. October 31. SVDA. 1993b. Underground Concrete Tanks at Building 502. Memorandum from J. Clarke. November 24. Uangst, R. 1989. Former SVDA Health and Safety Officer, Personal Communication with A. Leinbach, Dames & Moore. October 25.
Savanna Army Depot, Final ROD 4-2 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
URS. 2008a. SVAD-155, Building 729 CF Plant Drilling and Boostering Building Removal Site Evaluation and Engineering Evaluation/Cost Analysis. Savanna Army Depot Activity, Savanna, Illinois. March. URS. 2008b. SVAD-186, Building 707 CF Plant Generator Building Removal Site Evaluation and Engineering Evaluation/Cost Analysis. Savanna Army Depot Activity, Savanna, Illinois. March. URS. 2009. Removal Action Construction Report. SVAD-155, Building 729 CF Plant Drilling and Boostering Building, SVAD-186, Building 707 CF Plant Generator Building. Savanna Army Depot Activity, Savanna, Illinois. February. USATHAMA (U.S. Army Toxic and Hazardous Materials Agency). 1979. Installation Assessment of Savanna Army Depot Activity, Record Evaluation Report No. 134. January. USEPA (U.S. Environmental Protection Agency). 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA. October. USEPA. 2000. Data Quality Objectives Process for Hazardous Waste Site Investigations, Final. EPA QA/G- 4HW. EPA/600/R-00/007. USEPA. 2002. EPA Region 9 PRG tables and associated documentation (http://www.epa.gov/region09/waste/sfund/prg/index.html). USEPA. 2004. EPA Region 9 PRG tables and associated documentation (http://www.epa.gov/region09/waste/sfund/prg/index.html).
Savanna Army Depot, Final ROD 4-3 August 2013 Sites 5, 24, 37PS, 69, 76CS, 76OD, 126, 155, 184, and 186
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APPENDIX A HUMAN HEALTH RISK ASSESSMENT SUMMARY
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Table A-1. Human Health Risk Summaries Savanna Army Depot Activity, Savanna, Illinois Hazard Index Cancer Risk Recreational Residential Industrial Construction Recreational Residential Industrial Construction Site and Media Worker Worker Integrateda Integrateda Worker Worker Child Adult Child Adult Site 5 Surface Soil 2 × 10-7 1 × 10-8 1 × 10-7 8 × 10-7 0.002 0.002 0.005 0.0005 0.03 0.003 Subsurface Soil 4 × 10-10 3 × 10-11 NA 2 × 10-9 0.000004 0.000002 NA NA 0.00005 0.000006 Groundwater NA NA NA 3 × 10-6 NA NA NA NA 0.2 0.08 Plant Ingestion (surface soil) NA NA NA 4 × 10-6 NA NA NA NA 1.0 0.6 Plant Ingestion (subsurface soil) NA NA NA 3 × 10-8 NA NA NA NA 0.0004 0.0002 Total Surface Soil and 2 × 10-7 1 × 10-8 1 × 10-7 8 × 10-6 0.002 0.002 0.005 0.0005 1.0 0.6 Groundwater Total Subsurface Soil and 4 × 10-10 3 × 10-11 NA 3 × 10-6 0.000004 0.000002 NA NA 0.2 0.08 Groundwater Site 24 b -5 A Groundwater NA NA NA 2 × 10 NA NA NA NA 1.0 0.6 - 1
Site 37PS Surface Soil 2 × 10-5 2 × 10-6 1 × 10-5 8 × 10-5 0.06 0.08 0.2 0.02 1.0 0.1 Subsurface Soil 4 × 10-6 4 × 10-7 NA 2 × 10-5 0.02 0.04 NA NA 0.5 0.05 Plant Ingestion (surface soil) NA NA NA 8 × 10-4 NA NA NA NA 1.0 0.8 Plant Ingestion (subsurface soil) NA NA NA 3 × 10-4 NA NA NA NA 0.1 0.06 Total Surface Soil 2 × 10-5 2 × 10-6 1 × 10-5 9 × 10-4 0.06 0.08 0.2 0.02 3.0 1.0 Total Subsurface Soil 4 × 10-6 4 × 10-7 NA 3 × 10-4 0.02 0.04 NA NA 0.6 0.1 Site 69 Surface Soil 2 × 10-7 1 × 10-8 9 × 10-8 6 × 10-7 0.02 0.01 0.05 0.005 0.3 0.03 Plant Ingestion (surface soil) NA NA NA 1 × 10-4 NA NA NA NA 0.2 0.1 Total Surface Soil 2 × 10-7 1 × 10-8 9 × 10-8 1 × 10-4 0.02 0.01 0.05 0.005 0.5 0.1 Site 76CS Surface Soil 9 × 10-5 9 × 10-6 6 × 10-5 4 × 10-4 0.6 0.4 1.0 0.1 8.0 0.9 Subsurface Soil 6 × 10-6 5 × 10-7 NA 3 × 10-5 0.03 0.02 NA NA 0.4 0.05 Plant Ingestion (surface soil) NA NA NA 5 × 10-3 NA NA NA NA 20 10 Plant Ingestion (subsurface soil) NA NA NA 3 × 10-4 NA NA NA NA 1.0 0.7 Total Surface Soil 9 × 10-5 9 × 10-6 6 × 10-5 5 × 10-3 0.6 0.4 1.0 0.1 30 10 Total Subsurface Soil 6 × 10-6 5 × 10-7 NA 4 × 10-4 0.03 0.02 NA NA 2.0 0.8
Table A-1. Human Health Risk Summaries Savanna Army Depot Activity, Savanna, Illinois (Continued) Hazard Index Cancer Risk Recreational Residential Industrial Construction Recreational Residential Industrial Construction Site and Media Worker Worker Integrateda Integrateda Worker Worker Child Adult Child Adult Site 76OD Surface Soil 1 × 10-5 1 × 10-6 8 × 10-6 5 × 10-5 0.04 0.05 0.1 0.01 0.8 0.1 Subsurface Soil 1 × 10-6 1 × 10-7 NA 4 × 10-6 0.0008 0.0004 NA NA 0.007 0.001 Plant Ingestion (surface soil) NA NA NA 4 × 10-4 NA NA NA NA 3.0 2.0 Plant Ingestion (subsurface soil) NA NA NA 2 × 10-5 NA NA NA NA 0.04 0.02 Total Surface Soil 1 × 10-5 1 × 10-6 8 × 10-6 5 × 10-4 0.04 0.05 0.1 0.01 4.0 2.0 Total Subsurface Soil 1 × 10-6 1 × 10-7 NA 3 × 10-5 0.0008 0.0004 NA NA 0.05 0.02 Total Subsurface Soil and 6 × 10-6 1 × 10-7 NA 3 × 10-5 0.5 0.2 NA NA 60 30 Groundwater Site 126 A
- -5 -6 -6 -5 2 Surface Soil 1 × 10 1 × 10 7 × 10 5 × 10 0.0007 0.00009 0.002 0.0002 0.01 0.001
Subsurface Soil 4 × 10-5 4 × 10-6 NA 2 × 10-4 0.002 0.0002 NA NA 0.03 0.004 Plant Ingestion (surface soil) NA NA NA 1 × 10-3 NA NA NA NA 0.09 0.05 Plant Ingestion (subsurface soil) NA NA NA 5 × 10-3 NA NA NA NA 0.3 0.2 Total Surface Soil 1 × 10-5 1 × 10-6 7 × 10-6 1 × 10-3 0.0007 0.00009 0.002 0.0002 0.1 0.06 Total Subsurface Soil 4 × 10-5 4 × 10-6 NA 6 × 10-3 0.002 0.0002 NA NA 0.3 0.2 Site 155c Surface and Subsurface Soil NA NA NA 1 × 10-6 NA NA NA NA 0.006 NA Groundwater NA NA NA 1 × 10-5 NA NA NA NA 0.07 0.03 Total Soil and Groundwater NA NA NA 1 × 10-5 NA NA NA NA 0.08 0.03
Table A-1. Human Health Risk Summaries Savanna Army Depot Activity, Savanna, Illinois (Continued) Hazard Index Cancer Risk Recreational Residential Industrial Construction Recreational Residential Industrial Construction Site and Media Worker Worker Integrateda Integrateda Worker Worker Child Adult Child Adult Site 184 Surface Soil 3 × 10-7 2 × 10-8 2 × 10-7 1 × 10-6 0.02 0.02 0.05 0.006 0.3 0.04 Subsurface Soil 2 × 10-8 2 × 10-9 NA 9 × 10-8 0.0003 0.000005 NA NA 0.0002 0.00004 Plant Ingestion (surface soil) NA NA NA 3 × 10-5 NA NA NA NA 20 10 Plant Ingestion (subsurface soil) NA NA NA 4 × 10-6 NA NA NA NA 0.002 0.0009 Total Surface Soil 3 × 10-7 2 × 10-8 2 × 10-7 3 × 10-5 0.02 0.02 0.05 0.006 20 10 Total Subsurface Soil 2 × 10-8 2 × 10-9 NA 4 × 10-6 0.00003 0.000005 NA NA 0.002 0.001 Site 186d Surface and Subsurface Soil NA NA NA < 1 × 10-6 NA NA NA NA < 1 NA Notes: a An integrated receptor combines both child and adult exposures.
A b
- The baseline risk assessment for groundwater at Site 24 was conducted prior to the removal action. 3 c The residual risk assessment for Site 155 (conducted after the soil removal action was completed) calculated risks associated with soil confirmation sample concentrations exceeding the IEPA TACO residential Remedial Objectives; risks were calculated only for the resident child. d The residual risk assessment for Site 186 (conducted after the soil removal action was completed) compared confirmation samples to IEPA TACO residential Remedial Objectives; all sample concentrations within the top 15 feet BLS were below the Remedial Objectives. NA – pathway not evaluated.
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APPENDIX B
ECOLOGICAL RISK ASSESSMENT SUMMARY
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Table B-1. Ecological Risk Assessment Summary Savanna Army Depot Activity, Savanna, Illinois
Range of Hazard Quotients
Site Area 1 and <10 10-100 >100 Rationale for Recommendation Zinc and lead present potential risks to ecological receptors at Site 5. After factoring in AUFs, a realistic diet for robins and shrews, and use of more realistic exposure point concentrations, the HQs above 1 for lead and zinc range from 1.2 to 6.4. The terrestrial plant HQs also remain above 1 for lead (1.4) and zinc (3.2). In comparing the zinc and lead arithmetic mean concentrations (155 and 73.8 mg/kg, a respectively) to the ESVs for zinc (140 Site 5 0.3 acres Yes Yes None mg/kg) and lead (85 mg/kg), it is shown that the concentrations are 1.1 times the ESV (zinc) or less than the ESV (lead). This suggests that zinc and lead concentrations are not, as a whole, extremely elevated. The comparison of the arithmetic mean concentrations to the ESVs at Site 5, in combination with the small size of the site, suggests that zinc and lead would not be a concern to populations of robins and shrews. Given the small acreage (0.07 acres) at Site 37PS and the industrial nature of this area, it is unlikely that hawks, eagles, shrews, or robins b,c would spend a large amount of time foraging Site 37PS 0.07 acres Yes Yes None there; therefore, the HQs (all less than or equal to 53) greatly overestimate the risks to these species. Refinement of the food-chain analyses would result in all HQs at or below 2. Antimony presents potential risks to plants and shrews at Site 69 (HQ of 1.6 for plants; 6.6 for shrews). Given that antimony was detected only in 3 of 26 samples from 23 locations, exposure of receptors to elevated a Site 69 2.1 acres Yes None None concentrations of antimony is limited spatially. The chemicals without TRVs are not expected to be a concern because wildlife exposure would be limited spatially (HMX and 4-chloro-3-methylphenol) and sodium is an essential nutrient.
B-1
Table B-1. Ecological Risk Assessment Summary Savanna Army Depot Activity, Savanna, Illinois (Continued)
Range of Hazard Quotients
Site Area 1 and <10 10-100 >100 Rationale for Recommendation Antimony, arsenic, lead, selenium, thallium, and zinc present potential risk to the wildlife receptors at Site 76CS due to HQs greater than 1. Use of the realistic diet and AUF decreases the HQs for hawks and eagles from zinc to below 1; however, the HQs associated with robins and shrews from several metals remain above 1. Although the HQs remain above 1 from metals, the most elevated concentrations of the metals were d detected in soil borings among active railroad Site 76CS 2.9 acres Yes Yes None tracks. The concentrations of the metals in the grassy fields to the north and east of the railroad lines (which are more attractive to wildlife for foraging territory or cover) were all below their respective ESVs. Wildlife exposure to elevated concentrations of metals would be limited. The inhalation pathway is not of concern at Site 76CS as VOCs were not detected in the four samples collected from the soil depth interval in which burrows are expected to occur. Given the small acreage (0.23 acres) and the industrial nature of this site (between a parking lot and railroad tracks), it is unlikely that hawks, eagles, shrews, or robins would spend a large Site 76ODa,b 0.23 acres Yes Yes Yes amount of time foraging there; therefore, the HQs greatly overestimate the risks to these species. In addition, considering future land use plans, Site 76OD does not likely provide adequate quality habitat to support wildlife populations. e Site 126 0.29 acres None None None No HQs >1. Antimony, benzo(a)anthracene, benzo(a)pyrene, chrysene, DNBP, lead, and phenanthrene were the ecoCOPCs with calculated HQs equal to or above 1 . Results are based on conservative methods and are overestimates of exposure, as these receptors will range over larger areas and Site 155 will not be adequate in providing all of their dietary needs. After factoring in the use of f more realistic area use factors and use of a more Site 155 0.5 acres Yes Yes Yes realistic exposure point concentration and realistic diets, the HQs for all ecoCOPCs with toxicity reference values declined below 1, except for DNBP and lead. However, DNBP risks are heavily biased by the maximum sample detection. In addition, the presence of elevated lead in only one sample location and the arithmetic mean concentration below the ESV suggest that lead is not a concern at Site 155.
B-2
Table B-1. Ecological Risk Assessment Summary Savanna Army Depot Activity, Savanna, Illinois (Continued)
Range of Hazard Quotients
Site Area 1 and <10 10-100 >100 Rationale for Recommendation 0.018 acres Copper, lead, selenium, and zinc pose a potential risk to wildlife receptors due to HQs above 1. Use of more realistic exposure assumptions (i.e., AUFs, realistic diets, and the use of the arithmetic means rather than the maximum detected concentrations as the exposure point concentrations) would result in all of the HQs declining to or below 1 with one exception. The d surface soil HQ for robins from lead would Site 184 Yes Yes Yes decrease to 2.3. Given the extremely small size of Site 184 (a total 0.018 acres, which includes 0.004 acres for Building 640 and 0.014 acres of soil associated with the investigation area) and that the elevated concentrations of lead are located at the base of the soil excavation in close proximity of Building 640, wildlife exposure to elevated concentrations of lead would be extremely limited. a Source: SAIC 2009b. b Sites 37PS and 76OD were evaluated with Site 76CS due to their proximity. c Source: SAIC 2004. d Source: SAIC 2007c. e Source: SAIC 2007b. f Source: URS 2008a. The HQs presented are based on soil concentrations prior to the removal action.
B-3
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APPENDIX C
PUBLIC MEETING SIGN-IN SHEET, PUBLIC MEETING TRANSCRIPT,
AND
WRITTEN PUBLIC COMMENTS
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PUBLIC MEETING SIGN-IN SHEET
C-1 C-2 PUBLIC MEETING TRANSCRIPT
C-3 · · · · · · · · SAVANNA ARMY DEPOT ACTIVITY · · · · · · · PROPOSED PLAN FOR SITES 5, 24, 37PS, 69, · · · · · · 76CS, 76OD, 126, 155, 184, and 186 and · · · · · · PROPOSED PLAN FOR SITE 21BDP · · · In the Matter of the· · · · · ··) Savanna Army Depot · December 6, 2012 Public Meeting ) Savanna, Illinois · for Proposed Plan· · · · · · · ·) · · · · Present on behalf of USEPA/IEPA: · Tom Barounis · Charlene Falco · Clarence Smith · · · Present on behalf of SAIC: · Marcy Larriva · Linda Meredith · Rupa Price · · · Cathy Collins, Base Realignment and Closure · Environmental Coordinator · · · Others Present: · Jo Carey · Todd Knuth · Ray Ruthenberg · Ed Juracek · Alan Anderson · Ole Pace · · · · · · · Court Reporter:··Julie K. Edeus, CSR · · · ·
(815) 453-2260
C-4 Page 2
·1·· · · · · ·MS. COLLINS:··Good evening, Ladies and · · ·2·· · ·· Gentlemen.··My name is Cathy Collins.··I've · · ·3·· · ·· recently taken the -- well, tried to take the · · ·4·· · ·· place of John Clarke.··I'm the Base Realignment · · ·5·· · ·· and Closure Environmental Coordinator here at · · ·6·· · ·· the Savanna Army Depot also at the Newport · · ·7·· · ·· Chemical Depot in Indiana. · · ·8·· · · · · ·· This meeting is being conducted to · · ·9·· · ·· discuss the preferred remedial actions presented · · 10·· · ·· in the 11 proposed plan site report. · · 11·· · · · · ·The U.S. Army in conjunction with the U.S. · · 12·· · ·· Environmental Protection Agency represented by · · 13·· · ·· Mr. Tom Barounis -- please raise your hand -- · · 14·· · ·· and the Illinois Environmental Protection Agency · · 15·· · ·· represented by Ms. Charlene Falco and · · 16·· · ·· Mr. Clarence Smith is requesting public comment · · 17·· · ·· on the proposed plan. · · 18·· · · · · ·The plan was prepared in accordance with · · 19·· · ·· Section 117(a) of the Comprehensive · · 20·· · ·· Environmental Response Compensation and · · 21·· · ·· Liability Act (CERCLA) of 1980 and the National · · 22·· · ·· Oil and Hazardous Substance Pollution · · 23·· · ·· Contingency Plan which provide the opportunity · · 24·· · ·· for public input in the site decision-making · · · · (815) 453-2260 · · · · C-5 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 3
·1·· · ·· process. · · ·2·· · · · · ·The proposed plan summarizes the cleanup · · ·3·· · ·· or no further action alternatives evaluated in · · ·4·· · ·· the respective Remedial Investigation · · ·5·· · ·· Feasibility Study (RI/FS) performed on each site · · ·6·· · ·· and identifies the preferred remedy.··The · · ·7·· · ·· various RIFS reports are referenced in the · · ·8·· · ·· proposed plans and are available for public · · ·9·· · ·· review in the Hanover and Savanna public · · 10·· · ·· libraries. · · 11·· · · · · ·As part of the process required by CERCLA, · · 12·· · ·· the Army has established a 30-day comment period · · 13·· · ·· that began on 14 November and ends on 14 · · 14·· · ·· November (sic) 2012.··Written comments · · 15·· · ·· postmarked before midnight on that date will be · · 16·· · ·· considered.··After evaluating all the written · · 17·· · ·· comments submitted by the public, the Army, in · · 18·· · ·· conjunction with the USEPA and IEPA, will · · 19·· · ·· finalize the proposed alternative into a record · · 20·· · ·· of decision (ROD) or select another remedy based · · 21·· · ·· on the information or on the comments received · · 22·· · ·· from the public. · · 23·· · · · · ·I will now turn the time over to Marcy · · 24·· · ·· Larriva, SAIC, to present the proposed plans. · · · · (815) 453-2260 · · · · C-6 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 4
·1·· · · · · ·MS. LARRIVA:··Thank you.··As Cathy stated, · · ·2·· · ·· we have two proposed plans that we're presenting · · ·3·· · ·· today for this public meeting. · · ·4·· · · · · ·The first proposed plan has the ten sites · · ·5·· · ·· that are listed up there. · · ·6·· · · · · ·The second proposed plan is specific to · · ·7·· · ·· Site 21BDP and we decided to combine them · · ·8·· · ·· because of the timing that the documents came · · ·9·· · ·· out and were finalized. · · 10·· · · · · ·This is a slide that kind of goes over the · · 11·· · ·· key people that Cathy just presented to you · · 12·· · ·· guys.··SAIC has done a lot of the Remedial · · 13·· · ·· Investigation Feasibility Study out here.··I'm · · 14·· · ·· Marcy Larriva, I'm the project manager for most · · 15·· · ·· of the work being conducted out here.··Linda · · 16·· · ·· Meredith is one of our risk assessors.··And we · · 17·· · ·· got Rupa Price which is a feasibility study · · 18·· · ·· engineer.··They've all worked on these documents · · 19·· · ·· and the sites associated with it. · · 20·· · · · · ·The purpose of this meeting is to · · 21·· · ·· summarize the investigation activities, history · · 22·· · ·· and risk assessments and cleanup history for · · 23·· · ·· these sites and propose a recommendation for · · 24·· · ·· these sites.··The recommendations presented in · · · · (815) 453-2260 · · · · C-7 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 5
·1·· · ·· these plans have been agreed to and developed by · · ·2·· · ·· the Army, the USEPA and the IEPA and we're · · ·3·· · ·· encouraging the public participation and to · · ·4·· · ·· comment on these sites if you have any input you · · ·5·· · ·· want to give. · · ·6·· · · · · ·The regulatory background for this is it's · · ·7·· · ·· being driven by CERCLA.··It's a federal law · · ·8·· · ·· addressing the cleanup of environmentally · · ·9·· · ·· contaminated land.··And this site is an NPL site · · 10·· · ·· or it's listed on the National Priority List, so · · 11·· · ·· that's another reason it is following the CERCLA · · 12·· · ·· process.··It's all known as Superfund.··And · · 13·· · ·· that's one of the reasons we're going through · · 14·· · ·· these certain steps at these sites. · · 15·· · · · · ·This is kind of an overview of the CERCLA · · 16·· · ·· process.··The first step is to identify areas of · · 17·· · ·· potential contamination and based on that · · 18·· · ·· listing of being an NPL site, it then moves into · · 19·· · ·· the remedial investigation feasibility study · · 20·· · ·· where we go in, we collect samples, do · · 21·· · ·· investigation, then we analyze the need for a · · 22·· · ·· cleanup at the sites and we get to a decision · · 23·· · ·· point on these sites, we get to the proposed · · 24·· · ·· plan where we are on these 11 sites right now. · · · · (815) 453-2260 · · · · C-8 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 6
·1·· · ·· Once the proposed plan has got comments from the · · ·2·· · ·· community and has gotten acceptance from the · · ·3·· · ·· regulators, it will then go into a record of · · ·4·· · ·· decision to document what was decided for these · · ·5·· · ·· sites.··And then some of the sites that we're · · ·6·· · ·· presenting tonight are no further action, · · ·7·· · ·· they'll stop at that point and be closed out in · · ·8·· · ·· CERCLA.··Four of the sites will continue going · · ·9·· · ·· on until they get cleanup and are closed out in · · 10·· · ·· that way. · · 11·· · · · · ·A little background on Savanna.··Savanna · · 12·· · ·· was established as an army depot in 1917 for · · 13·· · ·· proof firing artillery pieces.··1918 it became · · 14·· · ·· an ordnance depot and then in 1939 is when a lot · · 15·· · ·· of the construction was done for the additional · · 16·· · ·· magazines and buildings associated with melt and · · 17·· · ·· pour operations and shell loading plants.··In · · 18·· · ·· 1995 the base was selected for closure under · · 19·· · ·· BRAC and it was officially closed in the spring · · 20·· · ·· of 2000. · · 21·· · · · · ·The current army activities on site are · · 22·· · ·· associated with assessing and the cleanup of · · 23·· · ·· potential contamination at the site and · · 24·· · ·· transferring the land. · · · · (815) 453-2260 · · · · C-9 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 7
·1·· · · · · ·This gives a big picture overview of the · · ·2·· · ·· intended land use at Savanna.··The majority of · · ·3·· · ·· the land will be going to the Fish and Wildlife · · ·4·· · ·· Service and then there's a small piece going to · · ·5·· · ·· IDNR.··The Corps of Engineers gets another small · · ·6·· · ·· piece and then about 20 percent of the land will · · ·7·· · ·· be going to the Land Reuse Authority and most of · · ·8·· · ·· that will be slated for industrial/commercial · · ·9·· · ·· use. · · 10·· · · · · ·Of the 11 sites being presented tonight, · · 11·· · ·· we've got 7 sites that -- 7 are transferring for · · 12·· · ·· industrial/commercial reuse.··We've got three · · 13·· · ·· sites that are going to the Fish and Wildlife · · 14·· · ·· Service and then we have one site that's across · · 15·· · ·· both Fish and Wildlife and industrial/commercial · · 16·· · ·· areas. · · 17·· · · · · ·This is a list of the 11 sites that we · · 18·· · ·· have presented in these two proposed plans.··And · · 19·· · ·· the next slide is a map of where these sites are · · 20·· · ·· located.··It's hard to see on here.··There's a · · 21·· · ·· big poster at the back of the room that shows · · 22·· · ·· the different sites and based on the colors on · · 23·· · ·· the site boundaries give you an indication on · · 24·· · ·· whether they're going for further action sites · · · · (815) 453-2260 · · · · C-10 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 8
·1·· · ·· or if they're green outlines that means they're · · ·2·· · ·· slated for no further action. · · ·3·· · · · · ·What I'm going to do now is kind of go · · ·4·· · ·· through just a high level of what type of · · ·5·· · ·· environmental investigations we do at sites in · · ·6·· · ·· general and specifically at these 11 sites.··Our · · ·7·· · ·· first step on most of these sites -- or all of · · ·8·· · ·· them is to do a baseline survey or historical · · ·9·· · ·· review of documents, talk with people on post · · 10·· · ·· that might have some indication of where · · 11·· · ·· contamination would be on the site.··Then we do · · 12·· · ·· a phased approach to sampling.··The first phase · · 13·· · ·· is usually targeting the most likely points of · · 14·· · ·· release and then we build on subsequent phases · · 15·· · ·· at that point to delineate the chemicals that · · 16·· · ·· are detected and determine if there's migration · · 17·· · ·· to other media, meaning from soil to the · · 18·· · ·· groundwater or to surface water or sediment · · 19·· · ·· bodies and then we determine based on that data · · 20·· · ·· any potential harm to humans and the · · 21·· · ·· environment.··The types of samples we collect · · 22·· · ·· are soil, groundwater, surface water sediment. · · 23·· · ·· Some of them we've also had structures such as · · 24·· · ·· sumps or septic tanks that we'll collect samples · · · · (815) 453-2260 · · · · C-11 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 9
·1·· · ·· from those structures also to determine if · · ·2·· · ·· there's a potential release from those.··All of · · ·3·· · ·· the sites in these two proposed plans have a · · ·4·· · ·· minimum of two phases of sampling at all of the · · ·5·· · ·· sites. · · ·6·· · · · · ·What I'm going to do now is just give you · · ·7·· · ·· a very brief overview of each one the sites in · · ·8·· · ·· this plan.··The presentation will show you the · · ·9·· · ·· site name, the activity and the chemicals · · 10·· · ·· detected and that was based on our · · 11·· · ·· investigation.··The first site is the one right · · 12·· · ·· here, it's Site No. 5 which is the liquid · · 13·· · ·· propellant burn area.··It was reportedly used · · 14·· · ·· for burning propellant, RFNA and UDMH.··I can · · 15·· · ·· tell you the chemical names, but they're really · · 16·· · ·· long.··We did surface water -- or I should say · · 17·· · ·· soil and groundwater sampling out there and · · 18·· · ·· there were multiple rounds of sampling between · · 19·· · ·· us and other contractors just based on the time · · 20·· · ·· phasing as they worked out. · · 21·· · · · · ·The next site which is one that looks like · · 22·· · ·· the road going down is the bomb disassembly · · 23·· · ·· plant.··What we had out there was the end of · · 24·· · ·· that road was used for disassembling bombs that · · · · (815) 453-2260 · · · · C-12 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 10
·1·· · ·· eventually went over to the TNT washout facility · · ·2·· · ·· down the road.··In addition to that area, we · · ·3·· · ·· also investigated three other subareas.··There · · ·4·· · ·· were two burn pads at that site as well as there · · ·5·· · ·· was function testing activities along the road · · ·6·· · ·· itself that we investigated. · · ·7·· · · · · ·This is Site 24, it was the CF Plant Melt · · ·8·· · ·· and Pour Facility.··This was used between 1941 · · ·9·· · ·· and 1945 to load six rounds of ammunition with · · 10·· · ·· explosives.··Subsequent to that following World · · 11·· · ·· War II, the building in that picture was · · 12·· · ·· renovated and used as an explosive washout plant · · 13·· · ·· from about 1948 until the mid-'50s.··This is a · · 14·· · ·· site that's had extensive sampling that was done · · 15·· · ·· based on the original sampling that was done of · · 16·· · ·· the soil and the groundwater.··It was determined · · 17·· · ·· a removal action needed to be conducted.··The · · 18·· · ·· removal action was conducted in 2003 by Cape · · 19·· · ·· Environmental.··They excavated approximately · · 20·· · ·· 1,775 cubic yards of explosives contaminated · · 21·· · ·· soil.··In 2002 there was also some sumps within · · 22·· · ·· the building that we cleaned out and removed of · · 23·· · ·· the residual explosives that were in there. · · 24·· · ·· After all of the excavation work was done inside · · · · (815) 453-2260 · · · · C-13 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 11
·1·· · ·· and outside, confirmation sampling was done to · · ·2·· · ·· ensure that we got to the cleanup goals that · · ·3·· · ·· were supposed to be. · · ·4·· · · · · ·This area also had a very large · · ·5·· · ·· groundwater investigation that was conducted · · ·6·· · ·· after the removal and prior to.··We did a lot of · · ·7·· · ·· hydropunch sampling which are temporary well · · ·8·· · ·· points.··You basically drill down, grab the · · ·9·· · ·· water sample and then remove it.··Based on that · · 10·· · ·· hydropunch sampling, we then installed permanent · · 11·· · ·· wells that were routinely sampled just to · · 12·· · ·· monitor what was going on as far as the · · 13·· · ·· groundwater explosives levels.··Based on that · · 14·· · ·· sampling we also did an assessment of potential · · 15·· · ·· releases to the Mississippi River because the · · 16·· · ·· ground water was migrating that direction.··The · · 17·· · ·· site was very close to the river at that point. · · 18·· · · · · ·This top corner picture is 37PS, it's the · · 19·· · ·· Pole Storage Area.··Basically it was in concrete · · 20·· · ·· areas and rails that they stored treated utility · · 21·· · ·· poles on. · · 22·· · · · · ·The one on the far side is Site 69.··It's · · 23·· · ·· a Contaminated Waste Processor.··That was · · 24·· · ·· utilized for treating or flashing.··It was a · · · · (815) 453-2260 · · · · C-14 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 12
·1·· · ·· furnace for burning explosives, potentially · · ·2·· · ·· flashing explosive contaminated materials or · · ·3·· · ·· even combustible materials like packing · · ·4·· · ·· materials and stuff. · · ·5·· · · · · ·Okay.··Here we have Site 76CS.··You can · · ·6·· · ·· even see -- it's kind of a rough picture.··It's · · ·7·· · ·· a Former Coal Storage Area that was here in the · · ·8·· · ·· lower post area.··Based on aerial photographs · · ·9·· · ·· there were piles of coal that were stored all · · 10·· · ·· along these railroad tracks. · · 11·· · · · · ·76OD on the far side.··This is an Open · · 12·· · ·· Drum Storage Area.··It was used for -- they were · · 13·· · ·· closed drums with hazardous materials like · · 14·· · ·· solvents and whatnot being stored out in the · · 15·· · ·· open and there was a potential for spills out · · 16·· · ·· there. · · 17·· · · · · ·Next we have -- this little building there · · 18·· · ·· is the CN Plant Boiler Building.··They were · · 19·· · ·· in-ground constructed underground storage tanks · · 20·· · ·· for fuel oil.··They are not part of the normal · · 21·· · ·· UST program because they were constructed in · · 22·· · ·· place, they weren't actually tanks that were · · 23·· · ·· buried.··And that was one of our investigation · · 24·· · ·· sites. · · · · (815) 453-2260 · · · · C-15 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 13
·1·· · · · · ·And then the far one is Site 155.··It's · · ·2·· · ·· the CF Plant Drilling and Boostering Building. · · ·3·· · ·· It was used to drill explosives and what they · · ·4·· · ·· would do is they would drill into explosives to · · ·5·· · ·· create a cavity for fuses.··SAIC did soil · · ·6·· · ·· investigation and groundwater investigation in · · ·7·· · ·· that area.··Based on those results, in 2008 URS · · ·8·· · ·· conducted a soil removal action out there and · · ·9·· · ·· did confirmation sampling at that point.··They · · 10·· · ·· excavated about 160 cubic yards of contaminated · · 11·· · ·· soils that had some PAHs and explosives and they · · 12·· · ·· were taken off-site.··There were samples · · 13·· · ·· collected from the area prior to backfilling the · · 14·· · ·· site. · · 15·· · · · · ·Next we have Site 184 right here.··It was · · 16·· · ·· the Compressor Building and the CL plant.··When · · 17·· · ·· we did a visual inspection as part of our · · 18·· · ·· investigation activities, there was a · · 19·· · ·· deteriorated drum outside of that building that · · 20·· · ·· it was suspected it came from the building · · 21·· · ·· itself.··When we went out and sampled, we · · 22·· · ·· removed the soil around the drum, removed the · · 23·· · ·· drum and then did the sampling underneath of · · 24·· · ·· that area. · · · · (815) 453-2260 · · · · C-16 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 14
·1·· · · · · ·The far side building is the CF Plant · · ·2·· · ·· Generator Building.··This is another site that · · ·3·· · ·· SAIC did some investigation activities.··Based · · ·4·· · ·· on those results, a removal action was conducted · · ·5·· · ·· in July of 2008 for contamination by URS.··About · · ·6·· · ·· 55 cubic yards of soil were excavated and taken · · ·7·· · ·· off-site and confirmation samples were collected · · ·8·· · ·· prior to backfilling the site. · · ·9·· · · · · ·That pretty much is an overview of the · · 10·· · ·· site history, some of what's been done at the · · 11·· · ·· sites as far as investigation and cleanups that · · 12·· · ·· have been conducted.··The data that we got from · · 13·· · ·· this investigation would then be evaluated as · · 14·· · ·· part of the risk assessment, so I'm going to · · 15·· · ·· have Linda Meredith go through those steps of · · 16·· · ·· the evaluation that was conducted. · · 17·· · · · · ·MS. MEREDITH:··We conducted two types of · · 18·· · ·· risk assessment at the sites, a human health · · 19·· · ·· risk assessment and an ecological risk · · 20·· · ·· assessment.··The human health risk assessment · · 21·· · ·· focussed on people and the ecological risk · · 22·· · ·· assessment focussed on wildlife.··The overall · · 23·· · ·· process is the same.··We followed this four-step · · 24·· · ·· process that's shown up here on the slide.··In · · · · (815) 453-2260 · · · · C-17 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 15
·1·· · ·· the first step, the data evaluation, we ask the · · ·2·· · ·· question do we have chemical constituents · · ·3·· · ·· present at these sites and if so, at what · · ·4·· · ·· concentrations and that's where our monitoring · · ·5·· · ·· data come and help us answer those questions. · · ·6·· · ·· The second step is the exposure assessment and · · ·7·· · ·· that's where we ask questions about who may be · · ·8·· · ·· exposed, are there people, are there wildlife · · ·9·· · ·· that come and visit these sites, how often are · · 10·· · ·· they coming, how long are they there, how much · · 11·· · ·· are they exposed.··The third step is the · · 12·· · ·· toxicity assessment.··We examine how harmful the · · 13·· · ·· chemicals are that were found there, you know, · · 14·· · ·· are they harmful and if so, how are they harmful · · 15·· · ·· and in what quantities.··And then all three of · · 16·· · ·· these steps are combined together and that helps · · 17·· · ·· answer the question are there risks to humans · · 18·· · ·· and wildlife. · · 19·· · · · · ·One thing I wanted to mention was we might · · 20·· · ·· have some sites -- in some cases we may have · · 21·· · ·· sites where we have chemicals present, but we · · 22·· · ·· don't have people or wildlife exposed to them. · · 23·· · ·· For example, we may have a situation where we · · 24·· · ·· have contamination that was found maybe deep in · · · · (815) 453-2260 · · · · C-18 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 16
·1·· · ·· the subsurface and so there's little exposure. · · ·2·· · ·· Or we could have a situation in which we have · · ·3·· · ·· chemicals that we found and people and wildlife · · ·4·· · ·· might be exposed to them, but that the chemicals · · ·5·· · ·· aren't harmful or they're not dangerous.··An · · ·6·· · ·· example might be where we have · · ·7·· · ·· naturally-occurring metals that are found in the · · ·8·· · ·· soil that may not be harmful to humans or to · · ·9·· · ·· wildlife. · · 10·· · · · · ·Let's talk a little bit about the human · · 11·· · ·· health risk assessment.··In the human health · · 12·· · ·· risk assessment we look at cancer risks, those · · 13·· · ·· chemicals that are carcinogens.··We also look at · · 14·· · ·· noncancer risks, so these are chemicals that · · 15·· · ·· although they might not cause cancer, they have · · 16·· · ·· a toxic effect, they are harmful to our bodies. · · 17·· · ·· They might, for example, target certain organs, · · 18·· · ·· like they might target the liver. · · 19·· · · · · ·We looked at different types of people who · · 20·· · ·· might come and use these sites.··We looked at · · 21·· · ·· workers.··Marcy mentioned that I think it was · · 22·· · ·· seven of these sites had -- the planned future · · 23·· · ·· use of these sites are industrial/commercial, so · · 24·· · ·· we looked at industrial/commercial workers.··We · · · · (815) 453-2260 · · · · C-19 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 17
·1·· · ·· also looked at construction workers because, for · · ·2·· · ·· example, if you're talking about soil, the · · ·3·· · ·· people who are doing the construction are in · · ·4·· · ·· greater contact with the soil so they would have · · ·5·· · ·· greater exposure.··We looked at recreational · · ·6·· · ·· visitors.··These could be people who might be · · ·7·· · ·· hiking at the site, they might be bird watching, · · ·8·· · ·· they might be picnicking.··We also looked at · · ·9·· · ·· residents which is not a part of the planned · · 10·· · ·· future use of the site, but we looked at that, · · 11·· · ·· we evaluated residents as a conservative · · 12·· · ·· measure. · · 13·· · · · · ·An ecological risk assessment -- this · · 14·· · ·· focuses on risks to wildlife.··One of the first · · 15·· · ·· things we do is we do an evaluation of habitat · · 16·· · ·· and we're trying to determine if there's enough · · 17·· · ·· habitat to support wildlife.··For example, if we · · 18·· · ·· have a site that's in the middle of a paved · · 19·· · ·· industrial area, then the habitat there is poor · · 20·· · ·· for wildlife.··We also look at the presence of · · 21·· · ·· chemicals that could be dangerous to wildlife. · · 22·· · ·· Mercury is an example of that.··We compare site · · 23·· · ·· concentrations to concentrations of chemicals · · 24·· · ·· that we know are safe and protective of · · · · (815) 453-2260 · · · · C-20 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 18
·1·· · ·· wildlife.··And these concentrations factor in · · ·2·· · ·· how much of a chemical wildlife will eat. · · ·3·· · · · · ·So for these 11 sites no further action or · · ·4·· · ·· no action is proposed at seven of the sites and · · ·5·· · ·· then remedial action is proposed at four.··And · · ·6·· · ·· so first of all, we're going to discuss the · · ·7·· · ·· seven sites at which no further action is · · ·8·· · ·· proposed and we'll talk first about the human · · ·9·· · ·· health risk assessment results.··I've looked at · · 10·· · ·· these sites in two different groups.··In the · · 11·· · ·· first group we have sites where no cleanup was · · 12·· · ·· needed based upon the results of the samples · · 13·· · ·· that we analyzed and the human health risk · · 14·· · ·· evaluation and that's the first four sites · · 15·· · ·· listed here.··In the following three sites -- · · 16·· · ·· actually Marcy mentioned this earlier -- we did · · 17·· · ·· have a removal action -- soil removal actions · · 18·· · ·· were conducted and the post cleanup · · 19·· · ·· concentrations don't cause harm to humans.··One · · 20·· · ·· of those was Site 24, the CF Plant Melt and Pour · · 21·· · ·· Facility and this -- it was in 2002 a soil · · 22·· · ·· removal action was conducted.··The sampling · · 23·· · ·· conducted after the removal action, those · · 24·· · ·· samples were evaluated and evaluated for risk · · · · (815) 453-2260 · · · · C-21 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 19
·1·· · ·· and those risks were acceptable.··They did not · · ·2·· · ·· cause harm to humans.··And the same at Sites -- · · ·3·· · ·· at the CF Plant Drilling and Boostering Building · · ·4·· · ·· and the CF Plant Generator Building, both of · · ·5·· · ·· those soil removal actions were conducted in · · ·6·· · ·· 2008 and the post cleanup sampling, the · · ·7·· · ·· confirmation sampling, those concentrations were · · ·8·· · ·· analyzed and they did not cause harm to humans. · · ·9·· · · · · ·Next we'll look at the ecological risk · · 10·· · ·· assessments for those same sites.··The · · 11·· · ·· ecological risk assessment found that there was · · 12·· · ·· existing habitat, but the concentrations are not · · 13·· · ·· harmful to wildlife.··They were below levels · · 14·· · ·· that were of concern.··And the reasons we have · · 15·· · ·· -- the reasons listed here and the first one, · · 16·· · ·· the concentrations of constituents were low at a · · 17·· · ·· number of the sites.··Sorry, I think I mentioned · · 18·· · ·· that. · · 19·· · · · · ·At Site 186 wildlife are not exposed to · · 20·· · ·· constituents.··This is a situation where we had · · 21·· · ·· contamination in the subsurface soil and we also · · 22·· · ·· had the presence of roads, buildings and · · 23·· · ·· pavement which served to limit wildlife · · 24·· · ·· exposure. · · · · (815) 453-2260 · · · · C-22 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 20
·1·· · · · · ·At two of the sites, 5 and 184, we had -- · · ·2·· · ·· the size of the site was small.··It was less · · ·3·· · ·· than .3 acres and so this serves to limit · · ·4·· · ·· exposure to wildlife because the area over which · · ·5·· · ·· the wildlife range or their foraging area where · · ·6·· · ·· they feed, that's a larger area so that they do · · ·7·· · ·· not spend all their time in the area of where · · ·8·· · ·· these chemicals were found.··The same at these · · ·9·· · ·· other three sites, 21BDP, 69 and 155 there were · · 10·· · ·· isolated areas where the contamination was · · 11·· · ·· found. · · 12·· · · · · ·And then at Site 24, that was the site · · 13·· · ·· Marcy had talked about where a soil removal · · 14·· · ·· action was conducted and so the soil is not a · · 15·· · ·· concern to wildlife.··An evaluation was done of · · 16·· · ·· the groundwater and how it would migrate to the · · 17·· · ·· Mississippi River and it was shown that once the · · 18·· · ·· concentrations reached the Mississippi River, · · 19·· · ·· they were not a concern to wildlife. · · 20·· · · · · ·So to summarize for these seven sites, · · 21·· · ·· both the results of the human health and the · · 22·· · ·· ecological risk assessment, the results · · 23·· · ·· recommended no action at these seven sites. · · 24·· · · · · ·So next we'll talk about the four sites · · · · (815) 453-2260 · · · · C-23 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 21
·1·· · ·· where remedial action is recommended.··And we'll · · ·2·· · ·· look first at the results of human health risk · · ·3·· · ·· assessment.··At these sites we looked at the · · ·4·· · ·· Pole Storage Area, that's 37PS, 76CS, the Coal · · ·5·· · ·· Storage Area and 76OD, the Open Drum Area. · · ·6·· · ·· Those three sites were grouped together, they're · · ·7·· · ·· adjacent to each other and you can see that on · · ·8·· · ·· your handout or on the map.··They also had · · ·9·· · ·· similar site conditions and contaminant · · 10·· · ·· characteristics.··So at these three sites the · · 11·· · ·· risks are generally driven by the Site 76CS · · 12·· · ·· risk.··That was the site that's the larger site, · · 13·· · ·· it has the highest risks.··The risks are highest · · 14·· · ·· for arsenic and chemicals known as polynuclear · · 15·· · ·· aromatic hydrocarbons, also known as PAHs. · · 16·· · ·· These risks were determined to be unacceptable. · · 17·· · ·· We also had an unacceptable risk for · · 18·· · ·· hypothetical residential land use.··And our · · 19·· · ·· chemicals of concern at those first three sites · · 20·· · ·· are PAHs and arsenic.··And then at Site 126 the · · 21·· · ·· chemicals of concern again were similar and the · · 22·· · ·· risks were similar to the other three sites. · · 23·· · ·· The risks were determined to be unacceptable and · · 24·· · ·· so consistent with the recommendation with the · · · · (815) 453-2260 · · · · C-24 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 22
·1·· · ·· other three, further action was recommended to · · ·2·· · ·· address the concern with the PAHs, the · · ·3·· · ·· polynuclear aromatic hydrocarbons, at that site. · · ·4·· · · · · ·And then the ecological risk assessment · · ·5·· · ·· results for these four sites, the ecological · · ·6·· · ·· risk assessment concluded something different. · · ·7·· · ·· They found that the existing concentrations do · · ·8·· · ·· not cause harm to the wildlife and required no · · ·9·· · ·· further action based upon the ecological risk · · 10·· · ·· assessment.··And the reasons for this were · · 11·· · ·· because the concentrations of constituents were · · 12·· · ·· low.··In particular at Site 126 we had limited · · 13·· · ·· habitat quality because these properties were in · · 14·· · ·· the middle of an industrial area.··You saw that · · 15·· · ·· like for 76CS and 37, 76OD, those were in the · · 16·· · ·· middle of railroad tracks where the coal storage · · 17·· · ·· was and then we also had small acreage, small · · 18·· · ·· area which serves to limit the exposure to the · · 19·· · ·· wildlife. · · 20·· · · · · ·And so in summary then for these four · · 21·· · ·· sites, the human health risk assessment · · 22·· · ·· recommended that further action be conducted and · · 23·· · ·· the ecological risk assessment recommended that · · 24·· · ·· no further action needed to be conducted. · · · · (815) 453-2260 · · · · C-25 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 23
·1·· · · · · ·And now I'm going to turn this over to · · ·2·· · ·· Rupa Price who's going to talk about the · · ·3·· · ·· feasibility study. · · ·4·· · · · · ·MS. PRICE:··The feasibility study is the · · ·5·· · ·· next step in the CERCLA process.··And the · · ·6·· · ·· purpose of it is to look at your cleanup · · ·7·· · ·· technologies -- for potential cleanup · · ·8·· · ·· technologies and develop alternatives that will · · ·9·· · ·· meet your cleanup objectives.··And we also need · · 10·· · ·· to comply with federal regulations. · · 11·· · · · · ·This is a snapshot of the feasibility · · 12·· · ·· process.··It's a pretty scripted process defined · · 13·· · ·· by CERCLA.··The first step is we determine what · · 14·· · ·· the site specific cleanup objective standards · · 15·· · ·· are and we identify the pertinent federal and · · 16·· · ·· state regulations which are also known as · · 17·· · ·· applicable or relevant and appropriate · · 18·· · ·· requirements, ARARs. · · 19·· · · · · ·We also identify potential remediation · · 20·· · ·· technologies and from there we go through a · · 21·· · ·· screening process to try to determine what our · · 22·· · ·· alternatives should be so that by the time we · · 23·· · ·· get to the detailed alternative evaluation, we · · 24·· · ·· have processes that make sense for our site. · · · · (815) 453-2260 · · · · C-26 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 24
·1·· · · · · ·Our cleanup objectives were to reduce soil · · ·2·· · ·· contamination to meet human health cleanup goals · · ·3·· · ·· and to achieve acceptable risk levels for the · · ·4·· · ·· planned future land use at these four sites · · ·5·· · ·· which are industrial/commercial sites and to · · ·6·· · ·· also prevent human exposure to contaminated soil · · ·7·· · ·· that would cause unacceptable risk. · · ·8·· · · · · ·These were the four alternatives that were · · ·9·· · ·· evaluated in this FS.··The first one is the no · · 10·· · ·· action alternative which is required to be · · 11·· · ·· evaluated as a baseline for the others.··The · · 12·· · ·· second alternative is the land use controls · · 13·· · ·· alternative which is a limited action · · 14·· · ·· alternative and it's simply administrative · · 15·· · ·· restrictions like these restrictions.··The third · · 16·· · ·· alternative is excavation and off-site disposal · · 17·· · ·· with land use controls.··So this would -- this · · 18·· · ·· alternative proposes excavating soil to meet · · 19·· · ·· industrial cleanup objectives and then · · 20·· · ·· implementing a land use control to restrict the · · 21·· · ·· land use to only industrial/commercial purposes. · · 22·· · ·· The fourth alternative is excavation and · · 23·· · ·· off-site disposal for unrestricted land use.··So · · 24·· · ·· this would excavate the soil to meet residential · · · · (815) 453-2260 · · · · C-27 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 25
·1·· · ·· cleanup objectives and you would not need a land · · ·2·· · ·· use control in place for that, it would be · · ·3·· · ·· unrestricted land use. · · ·4·· · · · · ·These are the nine evaluation criteria · · ·5·· · ·· that all of the alternatives are compared to. · · ·6·· · ·· The first two criteria are called threshold · · ·7·· · ·· criteria.··All of the alternatives have to meet · · ·8·· · ·· these criteria.··The next five are called our · · ·9·· · ·· balancing criteria.··The balancing criteria -- · · 10·· · ·· not all of the alternatives need to meet all of · · 11·· · ·· the balancing criteria, but we use that to · · 12·· · ·· determine what the best alternative is.··And · · 13·· · ·· then the last two are the modifying criteria and · · 14·· · ·· the modifying criteria helps us ensure that we · · 15·· · ·· have an alternative that's agreeable to · · 16·· · ·· regulators and the public. · · 17·· · · · · ·So I'm going to go through each of the · · 18·· · ·· criteria now in terms of the alternatives that · · 19·· · ·· we had picked -- or evaluated.··So the first two · · 20·· · ·· are the threshold criteria, again, overall · · 21·· · ·· protection of human health and environment.··And · · 22·· · ·· all of the alternatives, except for the no · · 23·· · ·· action alternative, are protective of human · · 24·· · ·· health and the environment because they either · · · · (815) 453-2260 · · · · C-28 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 26
·1·· · ·· remove the chemicals from the site or they limit · · ·2·· · ·· exposure to the chemicals.··And all the · · ·3·· · ·· alternatives, except for the no action · · ·4·· · ·· alternative, comply with the federal and state · · ·5·· · ·· regulations. · · ·6·· · · · · ·The next criteria is the long term · · ·7·· · ·· effectiveness and permanence.··The land use · · ·8·· · ·· controls, soil excavation with land use controls · · ·9·· · ·· and soil excavation to residential standards all · · 10·· · ·· have the potential to prove effective over the · · 11·· · ·· long term.··The alternatives involving the land · · 12·· · ·· use controls, the effectiveness -- the long term · · 13·· · ·· effectiveness is dependent on how well · · 14·· · ·· implemented the land use controls are, but soil · · 15·· · ·· excavation to residential standards is the most · · 16·· · ·· permanent. · · 17·· · · · · ·The next criteria is reduction of toxicity · · 18·· · ·· mobility or volume of contaminants through · · 19·· · ·· treatment.··None of the alternatives would · · 20·· · ·· eliminate toxicity of the contaminants, but · · 21·· · ·· because the alternatives involving off-site · · 22·· · ·· disposal the soil would be disposed at a · · 23·· · ·· licensed landfill, it reduces the mobility and · · 24·· · ·· volume of contaminants onsite. · · · · (815) 453-2260 · · · · C-29 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 27
·1·· · · · · ·Next is short term effectiveness.··The · · ·2·· · ·· land use control alternatives don't pose any · · ·3·· · ·· additional risk to the community, environment or · · ·4·· · ·· site workers during implementation, but the · · ·5·· · ·· alternatives involving off-site disposal have · · ·6·· · ·· some risk to the site workers when they're · · ·7·· · ·· operating the heavy equipment to do the · · ·8·· · ·· excavation and to the community when there's · · ·9·· · ·· transportation of contaminated soil on the · · 10·· · ·· public roads, but all of it would be mitigated · · 11·· · ·· with a health and safety plan. · · 12·· · · · · ·All the alternatives are readily · · 13·· · ·· implementable.··There's easy access to the · · 14·· · ·· equipment and personnel we would need for · · 15·· · ·· excavation and off-site disposal. · · 16·· · · · · ·Here we have a summary of the cost · · 17·· · ·· associated with the alternatives for 37PS, 76CS · · 18·· · ·· and 76OD and it's interesting to note that · · 19·· · ·· Alternatives 3 and 4, which are the excavation · · 20·· · ·· and off-site disposal alternatives, are very, · · 21·· · ·· very close in cost, but the remediation time · · 22·· · ·· frame are very different.··The excavation to -- · · 23·· · ·· for unrestricted use -- land use is only three · · 24·· · ·· years versus the 32 for -- for the alternative · · · · (815) 453-2260 · · · · C-30 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 28
·1·· · ·· with land use controls. · · ·2·· · · · · ·This is -- this is the cost and · · ·3·· · ·· remediation time frame summary for Site 126 and · · ·4·· · ·· here we'll note that the excavation and off-site · · ·5·· · ·· disposal for unrestricted use is actually the · · ·6·· · ·· least expensive option and it cleans up in the · · ·7·· · ·· shortest amount of time. · · ·8·· · · · · ·So here are the last two criteria, the · · ·9·· · ·· modifying criteria and based on regulating their · · 10·· · ·· concurrence with the remedial investigation, the · · 11·· · ·· feasible study and the proposed plan, we're at · · 12·· · ·· the point now of community acceptance and so · · 13·· · ·· once again, we're soliciting, you know, input · · 14·· · ·· and comments and questions from -- from the · · 15·· · ·· public.··So based on all of those nine criteria · · 16·· · ·· for all four sites, excavation and off-site · · 17·· · ·· disposal for unrestricted use is the recommended · · 18·· · ·· alternative.··The Army, the USEPA and IEPA are · · 19·· · ·· in agreement with the recommendation for the · · 20·· · ·· sites. · · 21·· · · · · ·Here we have a map of the proposed · · 22·· · ·· excavation area for 37PS, 76CS and 76OD.··It's · · 23·· · ·· kind of hard to see, but we have a handout that · · 24·· · ·· has the figure in there as well.··It's the only · · · · (815) 453-2260 · · · · C-31 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 29
·1·· · ·· one that opens up.··The excavation -- the · · ·2·· · ·· proposed excavation would remove approximately · · ·3·· · ·· 6,400 cubic yards of soil, but it is important · · ·4·· · ·· to note that this is only a proposed excavation · · ·5·· · ·· area.··There will be confirmatory sampling that · · ·6·· · ·· happens while excavation is happening to make · · ·7·· · ·· sure that we're meeting the residential cleanup · · ·8·· · ·· objectives. · · ·9·· · · · · ·Similarly, here is the proposed excavation · · 10·· · ·· area for Site 126 and same thing, confirmatory · · 11·· · ·· sampling to make sure that we're meeting the · · 12·· · ·· residential cleanup objectives. · · 13·· · · · · ·So to summarize, no further action is · · 14·· · ·· recommended at seven sites based on the · · 15·· · ·· environmental investigations and risk · · 16·· · ·· assessments.··There is remedial action · · 17·· · ·· recommended at four sites based on the human · · 18·· · ·· health risk assessments which is what we talked · · 19·· · ·· about and the Army, USEPA and IEPA are in · · 20·· · ·· agreement with the recommendations for all of · · 21·· · ·· these sites. · · 22·· · · · · ·So next we are going to consider and · · 23·· · ·· review the comments from the public at the end · · 24·· · ·· of the 30-day public review and all the final · · · · (815) 453-2260 · · · · C-32 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 30
·1·· · ·· decisions will be documented in a record of · · ·2·· · ·· decision.··The public comment period ends · · ·3·· · ·· December 14th, so if you have any questions, · · ·4·· · ·· comments or suggestions, please send them to · · ·5·· · ·· Ms. Cathy Collins at this address.··And we're · · ·6·· · ·· happy to take any questions that you might have · · ·7·· · ·· tonight, but there are also comment sheets at · · ·8·· · ·· the back of the room on the table and you're · · ·9·· · ·· welcome to fill them out and send them in and · · 10·· · ·· the address for Cathy Collins is on there as · · 11·· · ·· well.··But also feel free to ask us any · · 12·· · ·· questions you have tonight.··Thanks. · · 13·· · · · · ·MS. FALCO:··I wanted to clarify one point · · 14·· · ·· about the land use controls.··You saw there was · · 15·· · ·· a 32-year time limit associated with them, those · · 16·· · ·· land use controls would continue with the land · · 17·· · ·· essentially indefinitely or as long as the · · 18·· · ·· contaminants were there.··32 years is used as a · · 19·· · ·· time estimate by the Army in order to provide a · · 20·· · ·· cost estimate for the remedy.··You know, they · · 21·· · ·· have to draw a line somewhere essentially, but · · 22·· · ·· those land use controls would run with the land · · 23·· · ·· for as long as they needed to, so that would be · · 24·· · ·· the minimum essentially. · · · · (815) 453-2260 · · · · C-33 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 31
·1·· · · · · ·MR. JURACEK:··Let me identify myself.··I · · ·2·· · ·· notice we've got a court reporter.··My name is · · ·3·· · ·· Edward Juracek, spelled J-U-R-A-C-E-K.··I live · · ·4·· · ·· at 7253 Scenic Bluff Road in Savanna, Illinois · · ·5·· · ·· and I am a member of the -- the RAB.··And what · · ·6·· · ·· I'd like to comment about is, first of all, the · · ·7·· · ·· human health risk assessment -- for some reason · · ·8·· · ·· I did not pick up a recreational component in · · ·9·· · ·· that assessment that's relative to deer and · · 10·· · ·· turtles and anything else that might be · · 11·· · ·· captured, eaten, including fish that might be · · 12·· · ·· affected by the -- anything that goes into the · · 13·· · ·· Mississippi River due to Site No. 24.··Now, · · 14·· · ·· were any samples taken, anything analyzed · · 15·· · ·· relative to larger animals such as deer? · · 16·· · · · · ·MS. MEREDITH:··So are you -- what the · · 17·· · ·· human health risk assessment looked at was the · · 18·· · ·· -- the exposure of people that were doing · · 19·· · ·· recreational activities. · · 20·· · · · · ·MR. JURACEK:··That's correct.··Hunting · · 21·· · ·· happens to be a recreational activity as far as · · 22·· · ·· I know. · · 23·· · · · · ·MS. MEREDITH:··Correct.··So did -- we did · · 24·· · ·· not evaluate humans like, for example, eating -- · · · · (815) 453-2260 · · · · C-34 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 32
·1·· · ·· like hunting and then eating venison, we did not · · ·2·· · ·· evaluate that. · · ·3·· · · · · ·MR. JURACEK:··Okay.··So you did no · · ·4·· · ·· evaluation of -- of deer or any of those animals · · ·5·· · ·· at all? · · ·6·· · · · · ·MS. MEREDITH:··No, no, we didn't.··One of · · ·7·· · ·· the things to note about deer is they're largely · · ·8·· · ·· herbivorous and typically there's less uptake · · ·9·· · ·· into plants, so the reason why the ecological · · 10·· · ·· risk assessment focussed on its terrestrial -- · · 11·· · ·· they looked at the hawks, the eagles, the shrews · · 12·· · ·· and the robins is because there's more of a · · 13·· · ·· potential -- they were used as representative · · 14·· · ·· species and there's more of a potential for them · · 15·· · ·· to bioaccumulate because they're eating animals · · 16·· · ·· which are -- · · 17·· · · · · ·MR. JURACEK:··You're mixing two categories · · 18·· · ·· here what you're discussing -- or what you · · 19·· · ·· looked at in the environmental assessment.··I'm · · 20·· · ·· asking about the human health assessment. · · 21·· · · · · ·MS. MEREDITH:··Okay.··Well, I will say · · 22·· · ·· that the human health risk assessment did not · · 23·· · ·· evaluate ingestion of venison. · · 24·· · · · · ·MR. JURACEK:··All right.··If I could make · · · · (815) 453-2260 · · · · C-35 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 33
·1·· · ·· a recommendation that in the future that might · · ·2·· · ·· be something to consider. · · ·3·· · · · · ·MS. FALCO:··Well, for the washout lagoons · · ·4·· · ·· project -- the soil project and the TNT washout · · ·5·· · ·· lagoons that happened in 1992, '93, consumption · · ·6·· · ·· of deer meat was evaluated at that site, much · · ·7·· · ·· higher levels of the contaminants of concern, · · ·8·· · ·· much higher levels of TNT and it was shown in · · ·9·· · ·· that risk assessment to not be a concern and so, · · 10·· · ·· you know, we have -- you know, I've kind of · · 11·· · ·· taken that as sort of the touchstone and if it · · 12·· · ·· wasn't a concern at the washout lagoons, you · · 13·· · ·· know, I don't see it as really being a concern · · 14·· · ·· at some of these lesser contaminated sites. · · 15·· · · · · ·MR. JURACEK:··That's fine.··As long as the · · 16·· · ·· agencies agree, that's fine.··All right.··Thank · · 17·· · ·· you. · · 18·· · · · · ·MR. RUTHENBERG:··Ray Ruthenberg, Stockton · · 19·· · ·· and I'm on the R-A-B.··And I went over all the · · 20·· · ·· proposals and pretty much agree with the · · 21·· · ·· recommendation especially on the human effects. · · 22·· · · · · ·I do have questions on Site 5, Site 69 and · · 23·· · ·· Site 184.··Site 5, lead, zinc and carbon tet · · 24·· · ·· were detected and it appears that SAIC said · · · · (815) 453-2260 · · · · C-36 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 34
·1·· · ·· because it's a small area, don't worry about it. · · ·2·· · ·· I'm thinking that lead, zinc and perhaps carbon · · ·3·· · ·· tet are -- are not good for wildlife.··Site 69 · · ·4·· · ·· on Page 25 of the pamphlet, in the first column · · ·5·· · ·· about halfway down it says the produce ingestion · · ·6·· · ·· risks contain uncertainty.··And I just wondered · · ·7·· · ·· if you could comment on that. · · ·8·· · · · · ·MS. MEREDITH:··What we do is we evaluate a · · ·9·· · ·· resident living on that site and growing food in · · 10·· · ·· what would be a yard.··Those risks are very · · 11·· · ·· uncertain.··They use biotransfer factors.··These · · 12·· · ·· are the factors that we use that assume that a · · 13·· · ·· chemical that grows in the soil is taken up into · · 14·· · ·· a plant and those factors are conservative. · · 15·· · ·· There's a lot of conservative assumptions that · · 16·· · ·· are built into that assessment.··It assumes that · · 17·· · ·· a lot of what -- the produce that people eat are · · 18·· · ·· grown entirely on that site.··In some of the · · 19·· · ·· cases if the site is very small, it assumes that · · 20·· · ·· all the produce is grown in that very small · · 21·· · ·· contaminated area.··And so that's what I mean by · · 22·· · ·· some of the uncertainties that are associated · · 23·· · ·· with that produce assessment. · · 24·· · · · · ·MR. RUTHENBERG:··Finally Site 184 which is · · · · (815) 453-2260 · · · · C-37 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 35
·1·· · ·· an area of less than .018 acres, mercury was · · ·2·· · ·· detected, six metals were detected in the · · ·3·· · ·· surface soil with potential for adverse effects · · ·4·· · ·· to ecological receptors and Site 184 is a no · · ·5·· · ·· further remediation is recommended.··And that is · · ·6·· · ·· a concern to me because mercury is not very · · ·7·· · ·· good. · · ·8·· · · · · ·MS. MEREDITH:··I may -- I'm going to look · · ·9·· · ·· briefly.··I may need to spend a little bit more · · 10·· · ·· time and talk to my ecological risk assessor to · · 11·· · ·· provide a more thoughtful answer.··Basically we · · 12·· · ·· go through a process in the risk assessment -- · · 13·· · ·· the ecological risk assessment.··Initially it's · · 14·· · ·· very conservative.··Again, there's exposure · · 15·· · ·· assumptions.··It assumes that the wildlife spend · · 16·· · ·· all their time and all the food is found in that · · 17·· · ·· very small area.··Some of the diet assumptions, · · 18·· · ·· you know, what they eat -- for example, if they · · 19·· · ·· eat a certain percentage of worms and a certain · · 20·· · ·· percentage of other things, it assumes that the · · 21·· · ·· highest -- how shall I say this -- it assumes · · 22·· · ·· that what they eat -- the most contaminated · · 23·· · ·· thing is what -- is entirely what they eat.··So · · 24·· · ·· we kind of first run through the risk assessment · · · · (815) 453-2260 · · · · C-38 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 36
·1·· · ·· using conservative assumptions and then we go · · ·2·· · ·· through and we start to refine some of those · · ·3·· · ·· assumptions.··And I guess what I don't know · · ·4·· · ·· right now is exactly all of our findings at 184, · · ·5·· · ·· but I could certainly get back to you on that. · · ·6·· · · · · ·MR. RUTHENBERG:··One further question on · · ·7·· · ·· that.··Since it's such a small area, couldn't · · ·8·· · ·· the top 2 inches of the surface be shaved off · · ·9·· · ·· and hauled off-site and remove that uncertainty? · · 10·· · · · · ·MS. MEREDITH:··I think, again, it's -- · · 11·· · ·· it's the fact that we've evaluated this · · 12·· · ·· according to the criteria that's been set forth · · 13·· · ·· by the regulators and found that there isn't · · 14·· · ·· risk and so we feel -- and we are in agreement · · 15·· · ·· that that's not needed because the risk is · · 16·· · ·· acceptable there. · · 17·· · · · · ·MR. BAROUNIS:··This is Tom Barounis with · · 18·· · ·· the USEPA.··Ray, you're correct in theory.··Such · · 19·· · ·· a small area could be addressed so as to remove · · 20·· · ·· uncertainty.··The point that SAIC is making is · · 21·· · ·· that EPA makes -- you know, has to make · · 22·· · ·· consistently is that we require remedial · · 23·· · ·· responses when there's an unacceptable risk and · · 24·· · ·· the only way we can determine whether there's an · · · · (815) 453-2260 · · · · C-39 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 37
·1·· · ·· unacceptable risk to humans or to an ecological · · ·2·· · ·· receptor is by utilizing the best risk · · ·3·· · ·· calculation processes that we have using the · · ·4·· · ·· equations and when you plug the numbers into the · · ·5·· · ·· equations and for an ecological risk one of · · ·6·· · ·· those numbers is the area involved, you come out · · ·7·· · ·· with no credible potential risk to any receptor, · · ·8·· · ·· even though you may have a little bit of mercury · · ·9·· · ·· there.··So because the conclusion is that · · 10·· · ·· there's no credible risk that you could · · 11·· · ·· anticipate, we can't require -- we can't require · · 12·· · ·· that quick cleanup activity that you referred · · 13·· · ·· to. · · 14·· · · · · ·MR. RUTHENBERG:··Uh-huh.··That's all the · · 15·· · ·· questions I have. · · 16·· · · · · ·MR. PACE:··My name is Ole Pace.··I'm from · · 17·· · ·· Riverport Railroad and much of this activity · · 18·· · ·· appears to be in our future foot -- our existing · · 19·· · ·· footprint.··Would you just go ahead and tell me · · 20·· · ·· then -- and what is here looks substantially · · 21·· · ·· what we've understood to be the case and it · · 22·· · ·· appears to be moving along the decision tree · · 23·· · ·· here to ultimate resolution, particularly those · · 24·· · ·· sites where there's to be remediation.··Would · · · · (815) 453-2260 · · · · C-40 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 38
·1·· · ·· you tell me, again, what the next step is · · ·2·· · ·· following the public comment period.··I'm · · ·3·· · ·· presuming there's no substantial criticism or · · ·4·· · ·· concern about it.··Where do we go from here? · · ·5·· · · · · ·MS. LARRIVA:··The next step is to document · · ·6·· · ·· everything that's been pulled together and the · · ·7·· · ·· decisions are made in a ROD or a record of · · ·8·· · ·· decision and that's the decision point at CERCLA · · ·9·· · ·· from there on those particular sites.··The next · · 10·· · ·· step is doing a remedial design.··So basically · · 11·· · ·· it's laying out exactly how they're going to do · · 12·· · ·· the cleanup on the site.··So it goes remedial · · 13·· · ·· design after the ROD and then the cleanup and · · 14·· · ·· then they'll close out the site after they've · · 15·· · ·· done the confirmation sampling and do a · · 16·· · ·· construction completion report to say that · · 17·· · ·· they've met their goals of cleaning up the site. · · 18·· · · · · ·MR. PACE:··All right.··Thank you.··And one · · 19·· · ·· other question.··This -- a couple of these sites · · 20·· · ·· -- well, not a couple, but 126 and down where · · 21·· · ·· the coal was and so forth, I'm fascinated by the · · 22·· · ·· fact that coal is a contaminant, but I'm · · 23·· · ·· presuming that if you're not involved with the · · 24·· · ·· soil, stirring it up, breathing it, handling it, · · · · (815) 453-2260 · · · · C-41 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 39
·1·· · ·· whatever, that these sites don't -- if we're · · ·2·· · ·· there otherwise just on the surface, we're not · · ·3·· · ·· creating a risk to the people who are involved. · · ·4·· · · · · ·MS. MEREDITH:··Okay.··Is the question that · · ·5·· · ·· if there are, for example, people working there · · ·6·· · ·· is that a risk to people? · · ·7·· · · · · ·MR. PACE:··Right.··Do the people that are · · ·8·· · ·· running our railroad locomotives over the · · ·9·· · ·· railroad tracks that are on these properties -- · · 10·· · ·· at least some of them, are they at risk? · · 11·· · · · · ·MS. MEREDITH:··Well, some of the things we · · 12·· · ·· look at in the human health risk assessment is · · 13·· · ·· we look at, for example, if they're touching · · 14·· · ·· soil and they get soil on their hands and let's · · 15·· · ·· say later on in the day they're smoking a · · 16·· · ·· cigarette or somehow -- you know, so that they · · 17·· · ·· could be ingesting small amounts -- we call · · 18·· · ·· incidental ingestion -- small amounts of · · 19·· · ·· chemicals in the soil.··So some chemicals when · · 20·· · ·· they get on your skin, they can be absorbed · · 21·· · ·· through the skin.··Some chemicals when they're · · 22·· · ·· suspended in dust you can inhale them.··So the · · 23·· · ·· question as to whether they're a risk or not is · · 24·· · ·· something that we examine by looking at the · · · · (815) 453-2260 · · · · C-42 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 40
·1·· · ·· concentrations and as Tom mentioned, there's · · ·2·· · ·· equations that we do.··So we answer that · · ·3·· · ·· question on a site specific basis.··And so we · · ·4·· · ·· have decided at 76CS, that coal storage area, · · ·5·· · ·· that there could be some concern and that's why · · ·6·· · ·· we've recommended cleanup at that site. · · ·7·· · · · · ·MR. PACE:··I'm not -- I'm not quarrelling · · ·8·· · ·· with your conclusion, that's fine.··What I just · · ·9·· · ·· want to know is, you know, do I need to tell my · · 10·· · ·· crew to wear masks. · · 11·· · · · · ·MS. MEREDITH:··At 76CS? · · 12·· · · · · ·MR. PACE:··Yeah.··I mean, nobody ever has, · · 13·· · ·· but I would -- · · 14·· · · · · ·MS. MEREDITH:··That site had risks within · · 15·· · ·· what we call a target range when we were looking · · 16·· · ·· at cancer risks.··We were at the higher end of · · 17·· · ·· the risk range which is within EPA's acceptable · · 18·· · ·· range, but we decided that that was a site where · · 19·· · ·· we felt to be safe that we would recommend · · 20·· · ·· cleanup. · · 21·· · · · · ·MR. PACE:··Okay.··Well, see, I'm not · · 22·· · ·· quarrelling with that.··I mean, it's long since · · 23·· · ·· been the decision, so -- · · 24·· · · · · ·MR. BAROUNIS:··To give you a -- kind of a · · · · (815) 453-2260 · · · · C-43 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 41
·1·· · ·· summary -- an incomplete and summary kind of · · ·2·· · ·· response to your question about a concern at the · · ·3·· · ·· site, because the site has certain residual · · ·4·· · ·· chemicals from coal that are harmful to human · · ·5·· · ·· health, the equations that we use to determine · · ·6·· · ·· what the probability or what the potential risk · · ·7·· · ·· is take into account the body weight of the · · ·8·· · ·· person, how many hours a day that person is · · ·9·· · ·· likely to be there, how many days a year and how · · 10·· · ·· many years, so in what you might call a -- I · · 11·· · ·· don't want to call it a worst case scenario, but · · 12·· · ·· a most impacted kind of scenario, if one of your · · 13·· · ·· workers was there for eight hours a day, 250 · · 14·· · ·· days a year for years on end they could be at · · 15·· · ·· risk.··We want to prevent that kind of risk. · · 16·· · · · · ·MR. PACE:··No, I understand and I'm very · · 17·· · ·· comfortable with that, as I said.··So I · · 18·· · ·· understood what we're doing, but I just wanted · · 19·· · ·· to be sure there wasn't something all the sudden · · 20·· · ·· we were missing here because we take care of our · · 21·· · ·· troops.··Okay.··Thank you. · · 22·· · · · · ·MS. FALCO:··And we're not aware of any · · 23·· · ·· acute risks.··These risks are chronic. · · 24·· · · · · ·MR. BAROUNIS:··Long term, long term. · · · · (815) 453-2260 · · · · C-44 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 42
·1·· · · · · ·MR. PACE:··Thank you. · · ·2·· · · · · ·MS. MEREDITH:··For an industrial worker we · · ·3·· · ·· look at a 25-year period, so they are in that · · ·4·· · ·· area for 25 years. · · ·5·· · · · · ·MR. PACE:··All right, okay. · · ·6·· · · · · ·MS. MEREDITH:··250 days a year. · · ·7·· · · · · ·MR. PACE:··Thank you.··Thank you for the · · ·8·· · ·· presentation too.··This is Pace again.··But · · ·9·· · ·· thank you.··I appreciate this.··I appreciate the · · 10·· · ·· handouts and the materials, very helpful. · · 11·· · · · · ·MS. COLLINS:··Okay. · · 12·· · · · · ·MS. LARRIVA:··Any other questions? · · 13·· · · · · ·MR. BAROUNIS:··Again, if anybody has · · 14·· · ·· questions that come to them later that they wish · · 15·· · ·· they had asked, take a comment form, let the · · 16·· · ·· Army know, turn it in. · · 17·· · · · · ·MR. JURACEK:··Are we also discussing 21BDF · · 18·· · ·· today -- BDP? · · 19·· · · · · ·MS. LARRIVA:··Yeah.··I think that's it. · · 20·· · ·· We appreciate your attendance and participating. · · 21·· · · · · ·MS. COLLINS:··Adjourned. · · 22·· · · · · · · · · ·· (The meeting was concluded at · · 23·· · · · · · · · · · ·6:54 p.m.) · · 24·· · · · · (815) 453-2260 · · · · C-45 · · · · · · · · ·In Totidem Verbis, LLC (ITV) Page 43
·1·· · · · · · · · ·C E R T I F I C A T E · · ·2·· · · · · ·I, Julie K. Edeus, hereby certify that I · · ·3··am a Certified Shorthand Reporter of the State of · · ·4··Illinois; that I am the one who reported in · · ·5··shorthand the proceedings had or required to be kept · · ·6··in the above-entitled case; and that the above and · · ·7··foregoing is a full, true and complete transcript of · · ·8··my said shorthand notes so taken. · · ·9·· · · · · ·Dated at Dixon, Illinois, this 26th day of · · 10··December 2012. · · 11·· · · 12·· · · 13·· · · · · · · · · ·· Julie K. Edeus 14·· · · · · · · ·· Certified Shorthand Reporter · · · · · · · · ·· IL License No. 084-003820 15·· · · · · · · ·· P.O. Box 381 · · · · · · · · ·· Dixon, Illinois 61021 16·· · · 17·· · · 18·· · · 19·· · · 20·· · · 21·· · · 22·· · · 23·· · · 24·· · · · · (815) 453-2260 · · · · C-46 · · · · · · · · ·In Totidem Verbis, LLC (ITV) WRITTEN PUBLIC COMMENTS
C-47 Alequin, Rose Marie
From: Collins, Cathy M Miss CIV USA OSA [[email protected]] Sent: Monday, November 26, 2012 9:48 AM To: Leslie L LRL Roane Cc: Jo Ms CIV USA OSA Carey; Larriva, Monique M.; William T LRL Knuth Subject: Fwd: Proposed Plan comments
Leslie‐ I am forwarding Mr. Majors comments on the proposed plan for the 10 sites. I'm not sure at this time how these are managed, recorded/addressed at Savanna. Maybe you can address during the call tomorrow.
Cathy Collins ‐‐‐‐‐ Original Message ‐‐‐‐‐ From: Don Majors
> Ms. Cathy Collins > SVDA BRAC Environmental Coordinator > 18935 B Street > Savanna, Il. 61074 > > > > Name: Don Majors > Address: 20010 Rt. 84 N., Savanna, Il. 61074 > Affiliation: SVDA RAB > Phone: 815 273 2890 > > It appears to me that the proposed plan is sensible and thorough in > assessing and cleaning up the contamination with the available > information.I do have a couple of questions as to the information and > conclusions on which the clean up is based, and also on the > conclusions on pages 29 and 30 for the preferred remedy's. > > Regarding the Proposed Plan for > Sites 5, 24, 37PS, 69, 76CS, 69, 76OD, 126, 155, 184, and 186 > > comment on page 29,paragraph 3 under Human Health Risk Assessment > Results:Potential groundwater use is not considered relevant at this > site, and some others, but seems to be of possible importance at other > sites. > (Comments on groundwater on sites 5 and 24 indicate that groundwater > was considered relevant to future land use on this site, and water > quality was assessed.) > > comment on page 30 under Preferred remedy: > Soils were apparently assessed, but not groundwater. > > With the possibility of the present water system not being used in the 1 C-48 > future, there may be a need for the future land users to sink wells > for their use, whether industrial or residential. > > comment on Preferred Remedy statements on various sites: > As this is the final proposed plan, in the interest of clarity,it > would seem that the Preferred Remedy would contain an actual reference > to the preferred remedy, not i.e. " Evaluation of Site > 126 indicated that risks posed by chemicals detected at the site are > considered unacceptable to humans. Therefore, based on these results, > further remedial action or land use restriction is required." with no > reference to the remedial action being recommended. > > Regarding the Proposed Plan for > Sites 37PS, 76CS, and 76OD > > If I understand the map of the proposed excavation, the blue x's show > borings with excess contamination, and the red x's show borings > without excess contamination. > If this is the only measurement, especially along the east side of the > proposed excavation, why is there only one soil boring showing no > excess contamination. > It would seem that to find the boundaries of the contamination, that > there would be more borings needed, unless I am missing some other > method that was used to find the boundaries. >
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