US ARMY CORP OF ENGINEERS - RECORD OF DECISION (ROD) … · PMP Project Management Professional PRC...

us EPA RECORDS CENTER REGION 5

480187

Record of Decision Site 16 - SAA Deactivation Furnace and

Site 195 - Wildlife Area Sludge Application Area Savanna Army Depot Activity

Savanna, Illinois

Final

Prepared for:

THIS PAGE WAS INTENTIONALLY LEFT BLANK

Record of Decision Site 16 - SAA Deactivation Furnace and

Site 195 - Wildlife Area Sludge Application Area Savanna Army Depot Activity

Savanna, Illinois

Final

Prepared for:

U.S. Army Corps of Engineers Louisville District

Louisville, Kentucky 40202

Prepared by:

Leidos 11951 Freedom Drive

Reston, Virginia 20190

Contract No. W912QR-12-D-0020 Delivery Order No. 0009

Leidos CRN 300073

May 2014

CERTIFICATION 4 CONTRACTOR STATEMENT OF INDEPENDENT TECHNICAL REVIEW

Leidos has completed the Record of Decision for Sites 16 and 195 at Savanna Army Depot Activity, Savanna, Illinois. Notice is hereby given that an indeprendent technical review has been conducted that is appropriate to the level of risk and complexity inherent in the project as defined in the Leidos Quality Assurance Plan. During the independent techiiical 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 reasonableness of the results, including whether the product meets the customer's needs consistent with U.S. Army Corps of Engineers (USAGE) policy.

. Larriva, P.E., PMP Manager

May 19,2014 Date

:ph E. Peters Manager

May 19, 2014 Date

7^ Greg Tracey Independent Technical Review Team Leader

May 19, 2014 Date

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.

D. Jones-Bateman, PMP bgram Manager

May 19, 2014 Date

TABLE OF CONTENTS PAGE

1. DECLARATION OF THE RECORD OF DECISION 1-1

1.1 Installation Location 1-1 1.2 Statement of Basis and Purpose 1-1 1.3 Description of Selected Remedy and assessment of the site 1-1 1.4 Statutory Determinations 1-1 1.5 ROD Data Certification Checklist 1-3 1.6 Authorizing Signatures 1-4

2. DECISION SUMMARY 2-1 2.1 Installation History, Site Name, and Site Location 2-1 2.2 Site History and Regulatory Activities 2-5 2.3 Community Participation 2-5 2.4 Environmental Setting 2-6 2.5 Scope And Role Of Response Action 2-6 2.6 Site Descriptions 2-6

2.6.1 SAA Deactivation Furnace (Site 16) Site Description 2-6 2.6.2 Wildlife Area Sludge Application Area (Site 195) Site Description 2-8

2.7 Historical and Potential Future Land Uses 2-9 2.8 Summary of Site Risks 2-9

2.8.1 Summary of Site Risks - Site 16 2-9 2.8.1.1 Human Health Risk Assessment Results 2-9 2.8.1.2 Ecological Risk Assessment Results 2-10

2.8.2 Summary of Site Risks - Site 195 2-10 2.8.2.1 Human Health Risk Assessment Results 2-11 2.8.2.2 Ecological Risk Assessment Results 2-12

2.9 Description of the No Action Alternative 2-12 2.10 Statutory Determinations 2-13 2.11 Documentation of Significant Changes 2-13

3. RESPONSIVENESS SUMMARY 3-1 3.1 Background on Community Involvement 3-1 3.2 Summary of Public Comment Period and meeting 3-1

4. REFERENCES 4-1 Appendix A. Human Health Risk Summaries Appendix B. Public Meeting Sign-In Sheet and Public Meeting Transcript

Final ROD Sites 16 and 195 v May 2014 Savanna Anny Depot Activity

LIST OF FIGURES Page

Figure 1. Savanna Army Depot Activity Installation Location 1-2 Figure 2. Site 16 SAA Deactivation Furnace 2-3 Figure 3. Site 195 Wildlife Area Sludge Application Area 2-4

LIST OF TABLES Page

Table 1. Data Certification Checklist for Sites 16 and 195 Record of Decision 1-3 Table 2. Summary of Key Information for Sites 16 and 195 2-2 Table 3. Site 16 Ecological Risk Summary 2-11 Table 4. Site 195 Ecological Risk Summary 2-12

Final ROD Sites 16 and 195 vl May 2014 Savanna Army Depot Activity

ACRONYMS AND ABBREVIATIONS

2,4-D 2,4-Dichlorophenoxyacetic Acid APCS Air Pollution Control System APE Ammunition Peculiar Equipment ARAR Applicable or Relevant and Appropriate Requirements BCT BRAG Cleanup Team BERA Baseline Ecological Risk Assessment BLS Below Land Surface BRAC Base Realignment and Closure CDC Centers for Disease Control and Prevention CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information

System COPC Chemical of Potential Concern DOD U.S. Department of Defense EBS Environmental Baseline Survey ecoCOC Ecological Chemical of Concern ecoCOPC Ecological Chemical of Potential Concern ESV Ecological Screening Value FFA Federal Facility Agreement HE High Explosive HI Hazard Index HMX Cyclotetramethylene Tetranitramine HQ Hazard Quotient I.D. Identification lEPA Illinois Environmental Protection Agency IR Information Repository IRP Installation Restoration Program ISPCS Illinois State Plane Coordinate System LOAEL Lowest-Observable-Adverse-Effects Level LRA Local Redevelopment Authority pg/dL Micrograms per Deciliter MCPA 2-Methyl-4-chlorophenoxyacetic Acid mg/kg Milligrams per Kilogram NATO North Atlantic Treaty Organization NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List P.E. Professional Engineer PBT Persistent, Bioaccumulative, and Toxic PCB Polychlorinated Biphenyl PCP Pentachlorophenol PMP Project Management Professional PRC Preliminary Remediation Goal QA Quality Assurance RAB Restoration Advisory Board RCRA Resource Conservation and Recovery Act RDX Cyclo-1,3,5-trimethylene-2,4,5-trinitramine RI Remedial Investigation ROD Record of Decision SAA Small Arms Ammunition

Final ROD Sites 16 and 195 Savanna Army Depot Activity

VII May 2014

ACRONYMS AND ABBREVIATIONS (Continued)

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 TA'CO Tiered Approach to Corrective Action Objectives TCLP Toxicity Characteristic Leaching Procedure TNT 2,4,6-Trinitrotoluene UCL Upper Confidence Limit USEPA U.S. Enviromnental Protection Agency USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Society UST Underground Storage Tank VOC Volatile Organic Compound WP White Phosphorus


VIII May 2014

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The results of the baseline risk assessments conducted for both sites did not identify any unacceptable risks to human or ecological receptors identified for current or future land use scenarios. Based on these results, USEPA and the Army determined no action is necessary to protect public health or welfare or the environment. Therefore, the requirements of CERCLA Section 121 including the provisions of CERCLA Section 121(d)(2) concerning applicable or relevant and appropriate requirements (ARARs) are not applicable. In addition, there is no cost associated with the no action alternative. In addition, 5-year reviews are not required for the sites given the no action remedies will allow for unlimited use and unrestricted exposure.

1.5 ROD DATA CERTIFICATION CHECKLIST

A dafa certification checklist is provided in Table I. The checklist certifies that the ROD contains information pertinent to the remedy selection and identifies the ROD section within the body of this document. As a result of the decision not to select a remedial action, all of the requirements of a CERCLA data certification checklist are not triggered, since portions only apply in those cases where a remedial action is selected.

Table 1. Data Certification Checklist for Sites 16 and 195 Record of Decision Savanna Army Depot Activity, Savanna, Illinois

Information Information

in ROD ROD Section

Chemicals of Concem V Section 2.5

Baseline Risk V Section 2.8

Cleanup Levels NA

Source Materials NA

Current and Future Land Use Section 2.7

Land Use with Remedy NA

Implementation NA

Costs Associated with Remedy NA

Key Factors for Remedy Selection NA

NA: Information not required because sites require no action.


1-3 May 2014

1.6 AUTHORIZING SIGNATURES

No aotion is necessaiy to ensure protection of human health and the environment at Sites 16 and 195, as presented in this ROD. Concur and recommend for immediate implementation:

itraes E. Briggs i-cting Chief,-Reserve and Consolidations Branch

Base Realignment and Clostire Division

y\ rr-iT^

Richj/a Karl C Superfund Division Director

U.S. Environmental Protection Agency, Regioti 5

Lisa Bonnett ^isa Bonnett Director DEinois Environmeiital Protection Agency

Date

Final ROD Sites 16 and 195 Savanna Army Depot ActivTty

1-4 May 2014

2. DECISION SUMMARY

The Army is the lead agency responsible for remedial actions for Sites 16 and 195 proposed for no action under this ROD. USEPA and lEPA are support agencies and provide regulatory oversight, technical review, and concurrence as members of the BRAC Cleanup Team (BCT) for SVDA. The U.S. Department of Defense (DOD) is the source of cleanup-related funding.

2.1 INSTALLATION HISTORY, SITE NAME, AND SITE LOCATION

SVDA was a 13,062-acre 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 I). The CERCLIS I.D. number for SVDA is IL32I0020803.

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.

Site 16 consisted of the SAA Deactivation Furnace that included the following:

• Brass Reclamation Building (Building 941) • Two barricades (Buildings 942 and 943) • A cooling tower (Building 944) • A Small Items Deactivation Facility (Building 947) • Oil Pump Shelter (Building 948).

All of the buildings, with the exception of Building 941, have been removed. Site 16 was used to thermally treat SAA and reactive wastes (USEPA Waste Code D003), including explosive mixtures such as 2,4,6-trinitrotoluene (TNT), cyclo-l,3,5-trimethylene-2,4,6-trinitramine (RDX), cyclotetramethylene tetranitramine (HMX), and propellant mixtures, such as single- and double-base nitrocellulose, nitroguanadine, and black powder. The unit demilitarized SAA, including .50-caliber, .30-caliber, 7.62-mm North Atlantic Treaty Organization (NATO), .22-caliber, and 5.56-mm NATO. Other Class C or Hazard Class 1.4 items also were incinerated at this site (Westinghouse 1996). Planned future reuse of the site is industrial/commercial.

Site 195 was used for the land application of sanitary sludge from the Main Sewage Disposal Plant (Site 35) on the Lower Post. Sludge generated from the Main Sewage Disposal Plant was spread over the surface at Site 195 and three other application areas once a year from 1988 through 1996 (except 1995). The site has limited historical information and was used to grow corn for deer feed. Planned future reuse of the site is inclusion as part of the U.S. Fish and Wildlife Service (USFWS) wildlife management unit.

Table 2 summarizes key information for Sites 16 and 195 resolved for no action in this ROD, including sampling efforts, chemicals detected, and risk assessment recommendations. The site locations are shown in Figures 2 (Site 16) and 3 (Site 195).

Final ROD Sites 16 and 195 2-1 May 2014 Savanna Anuy Depot Activity

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Table 2. Summary of Key Information for Sites 16 and 195 Savanna Army Depot Activity, Savanna, illinois

16

Sam pling Conducted

Soil, groundwater

Chemical Constituents

Detected

Metals, Anions

Human Health Assessment'

For the planned future land use (Industrial/commercial) and hypothetical recreational and residential land uses, noncancer His are below the target HI and blood lead levels are below the level of concern. Cancer risks were not evaluated at Site 16 because none of the COPCs is associated with cancer effects. Therefore, human health risks are acceptable and no action Is recommended for the site.

Ecological Assessment'

The only HQs above 1 were for plants from lead concentrations In the surface soil. HQ results were only slightly above 1 and the mean concentration of lead was below the maximum detected upland background concentration. Wildlife exposure to elevated lead concentrations would be limited. Therefore, ecological risks are acceptable.

Supporting Documents

Installation Assessment (USATHAMA 1979) Closure Report for RCRA Closure of Deactivation Furnace APE 1236 (Westlnghouse 1996) Rl Report for the CL and CN Plant Area and Remaining LRA Parcel (SAIC 2007) Plant Area (Sites 16, 36, 47, and 84) BERA (SAIC 2011a) Proposed Plan for Site 16 - SAA Deactivation Furnace and Site 195-Wildlife Area Sludge Application Area (SAIC 2013)

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195 Soil SVOCs, Metals, Pesticides, Herbicides

For planned future use, cancer risks are within the target cancer risk range and noncancer His fall below the target HI, For the hypothetical residential land use, cancer risks fall within the acceptable target risk range and noncancer His exceed 1 due to the produce ingestion pathway. Produce risk estimates have a high degree of uncertainty and are generally considered biased high due primarily to the use of conservative blotransfer factors. Therefore, human health risks are acceptable and no action is recommended for the site.

The only HQs above 1 were for plants from aluminum and manganese, shrews from aluminum, and robins from MCPA concentrations In the surface and/or shallow subsurface soil. Aluminum Is not soluble and toxic In soil >5.5 pH and HQs for terrestrial plants from manganese In the surface and shallow subsurface soil were only slightly above 1. Actual presence of MCPA at Site 195 Is uncertain because of the analytical challenge posed by MCPA and the rapid degradation of the compound under conditions similar to those at Site 195. There are no migration pathways to more sensitive habitats. Therefore, ecological risks are acceptable.

Rl Report for the Upper Post Area (SAIC 2009) Sites 100 and 195 BERA (SAIC 2011b) Proposed Plan for Site 16 - SAA Deactivation Furnace and Site 195-Wildlife Area Sludge Application Area (SAIC 2013)

'Human health risk assessments are summarized In Section 2.8.1. ''Ecological risk assessments are summarized In Section 2.8.2.

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2.2 SITE HISTORY AND REGULATORY ACTIVITIES

In February 1995, the Secretary of Defense submitted a recommendation that SVDA be selected for closure. The Base Closure Act and Public Laws 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 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 environmental contamination prior to the release and reuse of the land. The scope of the investigation activities conducted at the 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. The investigation results and recommendations were presented for Site 16 in the R1 Report for the CL and CN Plant Areas and Remaining ERA Parcel (SAIC 2007) and for Site 195 in the R1 Report for the Upper Post Area (SAIC 2009). Upon completion, the documents were submitted to members of the BCT, the Anny, lEPA, and USEPA Region 5 for review and comments. Following a review of this information, the BCT concurred with the Army's proposed determination that no action is required at Sites 16 and 195.

2.3 COMMUNITY PARTICIPATION

Supporting documents describing field investigations, laboratory analysis results, risk assessments, and closure details are part of the SVDA Administrative Record and Information Repositories and are available for public review at the following locations:

• Savanna Public Library SVDA Information Repository 326 Third Street Savanna, IL 61074

• Hanover Township Library SVDA Information Repository 204 Jefferson Street Hanover, IL 61041

• Savanna Army Depot Activity SVDA Administrative Record Building 246 18935 B Street Savanna, IL 61074

The libraries are information repositories that contain only key documents relating to Sites 16 and 195. 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 September 2013. A public comment period for the Proposed Plan for Sites 16 and 195 was held from September 6 through October 6, 2013. In addition, a public meeting was held on September 25, 2013 in Building 247 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 lEPA were available to answer questions regarding concerns at the sites. Written public comments were not received on the Proposed Plan for Sites 16 and 195. The responsiveness summary is provided in Section 3. In addition, since 1995, Restoration Advisory Board (RAB) meetings that solicit a cross-section of the community are held at SVDA as needed. During these RAB meetings, the Army has apprised the community of the status of both Sites 16 and 195.

Final ROD Sites 16 andt 95 2-5 May 2014 Savanna Army Depot Activity

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. Site 16 is located in Carroll County and Site 195 is located in Jo Daviess County.

2.5 SCOPE AND ROLE OF RESPONSE ACTION

In 1989, an FFA was signed by the Army, lEPA, 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 lEPA. There are 127 Installation Restoration Program (IRP) sites at SVDA with 62 of these sites having achieved response complete. Two of these IRP sites are presented in this ROD.

Sites 16 and 195 presented in this ROD were evaluated in Rls completed between 1994 and 2011. No unacceptable ecological or human health risks were identified for current and anticipated future land use scenarios and, as a result, no action is being taken at Sites 16 and 195. This ROD presents the fmal response for these sites.

2.6 SITE DESCRIPTIONS

This section summarizes the characteristics of Sites 16 and 195 at SVDA, including the individual site history, summary of investigations, and closure activities. Site 16 is located in the southeastern portion of the Installation on West Road and Site 195 is located in the Upper Post Area.

2.6.1 SAA Deactivation Furnace (Site 16) Site Description

The SAA Deactivation Furnace (Site 16) (also referred to as the APE [Ammunition Peculiar Equipment] 1236 Deactivation Furnace, Brass Reclamation Plant, and Popping Plant) is located in the Plant Area of the Installation on West Road, as shown in Figure 2. Facilities at the SAA Deactivation Furnace included the Brass Reclamation Building (Building 941), two barricades (Buildings 942 and 943), and a cooling tower (Building 944), all built in 1954, and a Small Items Deactivation Facility (Building 947) and Oil Pump Shelter (Building 948) built in 1961. A 1955 historical report mentioned the installation of an exhaust system for the Brass Reclamation Plant (SOD 1955). All of the buildings with the exception of Building 941 have been removed. SAA Deactivation Furnace (Site 16)


2-6 May 2014

A former employee indicated that a cooling tower and two furnaces from the CR Plant (Site 33) were relocated to the Popping Plant (Hagerty 1996). These furnaces are not the same as the APE 1236 Deactivation Furnace. The APE 1236 Deactivation Furnace began operating in 1963 and was in RCRA interim status from November 1980 until 1995. It was used to thermally treat SAA and reactive wastes (USEPA Waste Code D003), including explosive mixtures such as TNT, RDX, HMX, and propellant mixtures, such as single- and double-base nitrocellulose, nitroguanadine, and black powder. In August 1988, an explosion disabled the fiimace. The furnace consisted of two trains, containing an ammunition feed system, a rotary effect, a scrap metal and ash handling system, and an air pollution control system (APCS). The unit demilitarized SAA, including .50-caliber, .30-caliber, 7.62-mm NATO, .22-caliber, and 5.56-mm NATO. Other Class C or Hazard Class 1.4 items also were incinerated at this site (Westinghouse 1996).

Historical maps indicated that the Building 941 septic system, consisting of a 4,500-gallon septic tank, 420-gallon siphon tank, and tile field, was north of Building 941 (SOD 1958 and 1975). The Building 941 septic system was investigated as a separate effort as Site I6S. The results of this investigation were presented in the No Further Action Decision Document for Sites 16S, 34, and 123 (SAIC2006). A walking survey was conducted near Building 941 in conjunction with the EBS. The EBS noted that the interior of Building 941 was clean, with concrete floors that appeared to be free of cracks and in good condition (SAIC 1999).

Soil sampling was conducted at Site 16 in 1990, 1991, 1992, and 1994 (prior to remediation) to characterize the horizontal and vertical extent of contamination. Sampling indicated that shallow surface soils (0 to 0.5 feet below land surface [BLS]) had been adversely affected by operation of the SAA Deactivation Furnace and elevated concentrations of lead, cadmium, chromium, and mercury were detected.

RCRA closure activities were conducted at Site 16 in the fall of 1995 and winter of 1996. The RCRA closure activities involved removal of the deactivation incinerator, its concrete pad, and two underground storage tanks (USTs), and excavation of contaminated soil surrounding the incinerator. Excavated soils containing between 0.3 and 5 mg/L of lead, using the toxicity characteristic leaching procedure (TCLP), were disposed of as special waste (Westinghouse 1996).

The RCRA closure of Site 16 did not require confirmatory samples because four rounds of sampling prior to remediation had adequately characterized the depths of concern for the RCRA program. However, RCRA characterization data were analyzed only for TCLP metals. Therefore, in order to appropriately assess risk, particularly for ecological receptors, the BCT requested that additional data be collected from outside the areas excavated during remediation. In addition, no previous groundwater investigations had been conducted at Site 16 to assess potential releases.

Leidos conducted field investigations at Site 16 in the fall of 1998 and summer of 1999. Thirty surface and three subsurface soil samples were collected and analyzed for metals. In addition, four groundwater monitoring wells were installed and sampled in November 1998 and August 1999 and analyzed for metals, volatile organic compounds (VOCs), explosives, and anions. Sampling locations are shown in Figure 2.

Only lead and selenium were detected at concentrations distinguishable from background and above the risk-based screening criteria. Concentrations of selenium exceeded the ecological screening value (ESV) and concentrations of lead exceeded protection of human health screening criteria and the ESV. The majority of these exceedances were in the surface soils in the northern portion of the site; in one case, selenium was detected in a subsurface soil at a concentration that exceeded the ESV. Lead failed the residential human health screen at only one location at Site 16.

An analysis was conducted of the potential for metal constituents in the soil to migrate to the groundwater in the future at Site 16. Selenium was detected at concentrations that exceed the screening

Final ROD Sites 16 and 195 2-7 May 2014 Savanna Army Depot Activity

values for migration to groundwater in four surface soil samples as well as one of the tliree excavation/ confirmation borings; however, detected concentrations were only slightly above the Region 9 preliminary remediation goal (PRG) screening criteria for migration to groundwater and not above the Tiered Approach to Corrective Action Objectives (TACO) migration to groundwater values. Based on the low concentrations, infrequent detections, nearly neutral pH (pH of 7.74), and depth to groundwater in this area (35 to 45 feet), the selenium detected in the soils at Site 16 is not expected to migrate to groundwater.

Site-related chemical constituents were not detected in groundwater underlying Site 16. Furthermore, although selenium was detected in soil samples at concentrations exceeding the screening criteria for migration to groundwater, it was not detected in the groundwater samples. Selenium concentrations in the soil do not pose an unacceptable risk from direct contact. The absence of detections of any VOCs, explosives, or site-related metals indicates that groundwater underlying the site area has not been affected by operations at Site 16.

2.6.2 Wildlife Area Sludge Application Area (Site 195) Site Description

The Wildlife Area Sludge Application Area (Site 195) (location shown in Figure 3) was used for the land application of sanitary sludge from the Main Sewage Disposal Plant (Site 35) on the Lower Post. Sludge generated from the Main Sewage Disposal Plant was spread over the surface at Site 195 and three other application areas once a year from 1988 through 1996 (except 1995). The site has limited historical information and has been used to grow com for deer feed.

Prior to 1977, the sludge drying beds at Site 35 were for optional or temporary use; however, common practice was to remove the sludge in a semi-solid state to tankers for transport to croplands for dispersal (USEPA 1977). From 1978 to approximately 1980, the digested sludge Wildlife Area Sludge Application Area was disposed of in a landfill (lEPA 1980). (Site 195) Compliance inspections conducted by lEPA Savanna Army Depot Activity, Savanna, Illinois between 1980 and 1984 indicated that the digested sludge either was drawn for wet hauling or was directed to three 22- by 10-foot drying beds at Site 35 (lEPA 1980, 1983, and 1984). From 1984 to 1988, the digester sludge was land applied at the application areas without a permit (lEPA 1984 and 1985, USEPA 1987). A 1987 compliance inspection noted that sludge beds at Site 35 were not being used and were full of sludge and grass. At this time, the sludge was being wet hauled offsite as necessary (USEPA 1987). The permit for the onsite land application of sludge was in effect as of May 4, 1988 (lEPA 1988).

In June 2001, investigation activities were conducted at Site 195 by Leidos. The sampling included drilling 10 soil borings on a triangular grid established over the sludge application area (Figure 3). Surface and shallow subsurface soil samples were analyzed for semivolatile organic compounds (SVOCs), polychlorinated biphenyls (PCBs), metals, pesticides, and herbicides. In addition, two pH samples were collected.

Site-related metals concentrations detected in surface and subsurface soil at Site 195 do not exceed Installation or regional (lEPA 2002) maximum background concentrations. Organic compounds detected consist predominantly of pesticides and herbicides with isolated SVOCs. Localized concentrations of herbicides, pesticides, or SVOCs exceed ecological or migration to groundwater screening criteria.


2-8 May 2014

2,4-Dichlorophenoxyacetic acid (2,4-D) and pentachlorophenol (PCP) were detected in the surface and shallow subsurface soil at concentrations exceeding the ESV. 2-Methyl-4-chlorophenoxyacetic acid (MCPA) and PCP concentrations exceeded migration to groundwater screening criteria. The presence of these compounds may be a result of herbicide and pesticide applications to the sludge area. MCPA does not appear to be migrating vertically because it was not detected in the shallow subsurface soil.

2.7 HISTORICAL AND POTENTIAL FUTURE LAND USES

SVDA was a 13,062-acre Installation that closed in March 2000. Former land use on the Lower Post and Plant Areas at SVDA consisted of manufacturing facilities and building complexes dedicated to loading bombs (CL Plant); completion of shell loadings (CP Plant); and an ammonium nitrate crystallization plant (CN Plant) all built and operated between 1939 and 1945. The CN Plant never operated as designed and was used for the disassembly, packing, and crating of 105-mm ammunition, including projectiles filled with high explosives (HE), mustard, and white phosphorus (WP) (USACE 1999). Site 16 is in the southeastern portion of SVDA west of the CN Plant Area.

Former land use on the Upper Post at SVDA consisted predominantly of ammunition storage, explosives washout facilities, bum and waste burial sites, bomb disassembly facilities, melt and pour facilities, and test ranges. Bottomland facilities on the Upper Post consisted of detonation and buming ground site areas. The current and future Upper Post recreational land uses include hunting, fishing, and boating. 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 adjacent to the Installation consists of livestock (i.e., beef cattle) and crop farming (i.e., com, soybeans, wheat, hay, and oats). Site 195 is in the Upper Post portion of SVDA.

The Local Redevelopment Plan (ERA 1997) and Reuse Plan Map (MSA 1999, revised by SAIC 2012) have identified a variety of reuse altematives for the land and facilities at SVDA. Site 16 will be developed for commercial/industrial use. Site 195 will be developed as a USFWS wildlife management unit.

2.8 SUMMARY OF SITE RISKS

Data screening and human health and ecological risk assessments were conducted for Sites 16 and 195. The human health and ecological evaluations are summarized in the following sections.

2.8.1 Summary of Site Risks - Site 16

A baseline human health risk assessment and screening-level ecological risk assessment (SERA) were conducted for Site 16 as part of the R1 Report for the CL and CN Plant Areas and Remaining LRA Parcel (SAIC 2007). In addition, a baseline ecological risk assessment (BERA) was conducted at Site 16 as part of the Plant Area (Sites 16, 36, 47, and 84) BERA (SAIC 201 la).

2.8.1.1 Human Health Risk Assessment Results

Site 16 surrounds an area that contains a septic system (referred to as Site 16S). The soil associated with the septic system (Site 16S) was investigated separately (before the CL and CN Plant Areas R1 Report in which Site 16 is evaluated) and a recommendation for no action was made in the No Further Action Decision Document for Sites 16S, 34, and 123 (SAIC 2006) because no adverse impacts to human health and the environment were found. Due to the separate investigation and no action conclusion, the Site 16S soil was not evaluated as part of Site 16 in the CL and CN Plant Areas R1 Report. In addition. Building 941 was not evaluated as part of the Site 16 human health risk assessment.

The Site 16 human health risk assessment evaluated the exposure of industrial and construction workers to soil based on the planned future industrial/commercial use for this site. An assessment of


recreational receptors and residents exposed to soil and residents exposed to groundwater also was conducted, although these risks are hypothetical given the planned future land use.

Cancer risks for soil and groundwater were not evaluated at Site 16 because none of the chemicals of potential concern (COPCs) is associated with cancer effects. For scenarios evaluated in accordance with the planned future reuse of the site (i.e., industrial and construction scenarios), noncancer hazard indices (His) fall below the target HI of I and the mean concentration of lead in soil is below USEPA's residential soil screening level for lead of 400 parts per million (ppm). For the recreational scenario and unrestricted land use scenario (i.e., residential), noncancer His also are below the target HI of 1 and the mean concentration of lead in soil is below USEPA's residential soil screening level for lead of 400 ppm.

The results of the human health risk assessment are summarized in Appendix A. In summary, the human health risks from the soil and groundwater at Site 16 are acceptable for all receptors.

2.8.1.2 Ecological Risk Assessment Results

A SERA and BERA were conducted for Site 16 as part of the RI Report for the CL and CN Plant Areas and Remaining ERA Parcel (SAIC 2007) and Plant Area (Sites 16, 36, 47, and 84) BERA (SAIC 201 la), respectively. In the SERA, an analysis of habitat available at Site 16 found sufficient acreage and quality of habitat to support terrestrial wildlife. In addition, state-listed endangered plant species are present at the site. The ecological risk screening identified three ecological chemicals of potential concern (ecoCOPCs) (lead, selenium, and calcium) in surface soil and/or shallow subsurface soil. No persistent, bioaccumulative, and toxic (PBT) chemicals were identified. The SERA indicated that there were no constituents in the shallow subsurface soil that presented potential risks to ecological receptors. However, there were a number of factors indicating a BERA was warranted for the surface soil at Site 16.

The potential ecological chemical of concern (ecoCOC) resulting from the BERA is lead. The potential ecoCOCs identified in the BERA are those chemicals with hazard quotients (HQs) above 1 from the lowest-observable-adverse-effects level (LOAEL)-based results using the lower of 95 percent upper confidence limits (UCLs) and the arithmetic means as exposure point concentrations. Despite the presence of lead as a potential ecoCOC, it was not identified as one in surface soil and Site 16 is recommended for no action from an ecological perspective based on the following:

• There were no concerns for ecological receptors exposed to residual surface soil (based on sampling conducted after a soil removal action was completed at Site 16 [SAIC 201 la]).

• The only HQ above 1 (lead for plants) was only slightly above 1 (2.0).

• The arithmetic mean concentration of lead was below the maximum detected upland background concentration.

• State-endangered plants were growing at the site. Additional remedial activities at Site 16 could remove some of the state-endangered plants. The presence of the plants at the site indicates the plant populations can flourish with the current concentrations of the potential ecoCOC.

• There were no migration pathways to more sensitive habitats.

The results of the ecological risk assessment are summarized in Table 3. In summary, the ecological risks fi-om the soil at Site 16 are acceptable.

2.8.2 Summary of Site Risks - Site 195

A baseline human health risk assessment and SERA were conducted at Site 195 as part of the Upper Post RI Report (SAIC 2009). In addition, a BERA was conducted as part of the Sites 100 and 195 BERA (SAIC 2011b).


Table 3. Site 16 Ecological Risk Summary Savanna Army Depot Activity, Savanna, Illinois

Area (acres)

Range of Hazard Quotients

land <10 ' 10-100 >100 i

Rationale for Recommendation

8,6 Yes - Lead None None Lead in the surface soil is the only potential ecoCOC. Although significant ecological resources are present at the site, Site 16 is recommended for no action because there are no wildlife HQs above 1, there was only a single plant HQ above 1, previous soil remediation at the site has removed the most elevated concentrations of metals, and there are no migration pathways to more sensitive habitats.

2.8.2.1 Human Health Risk Assessment Results

The human health risk assessment evaluated exposure of recreational receptors, industrial workers, and construction workers to soil based on the planned future inclusion of this site as part of a USFWS wildlife management unit. An assessment of residents exposed to soil also was conducted, although risks are hypothetical given the planned future land use.

For scenarios evaluated in accordance with the planned future reuse of the site (i.e., recreational, industrial, and construction scenarios), cancer risks are at the low end or below the target cancer risk range. Noncancer His fall below the target HI.

For the unrestricted reuse scenario (i.e., residential), cancer risks fall within the target cancer risk range due to the presence of arsenic and noncancer His exceed the target HI. Noncancer His exceeding the target are due primarily to ingestion of soil and produce containing MCPA and manganese.

The R1 recommendation and site risks for Site 195 were re-evaluated and documented in the Proposed Plan (SAIC 2013) and no action is recommended for soil at Site 195 from a human health perspective for the following reasons:

• Arsenic concentrations in surface and subsurface soil are responsible for industrial worker, recreational receptor, and resident cancer risks within the acceptable target risk range. The arsenic concentrations detected in the site soil samples range from 2.3 to 4.4 milligrams per kilogram (mg/kg) and all results fall below the state background arsenic concentration of 11.3 mg/kg for counties outside metropolitan statistical areas (lEPA 2002). Therefore, arsenic concentrations at the site are representative of naturally occurring background concentrations.

• Ingestion of produce containing MCPA and manganese is the primary pathway responsible for His exceeding the target of 1. These risks are associated with considerable uncertainty and are generally considered biased high due primarily to the use of conservative biotransfer factors that predict uptake into produce from concentrations in the soil. In addition, the maximum detected concentrations of MCPA in surface soil (22.3 mg/kg) and manganese in surface soil (1,090 mg/kg) are below their respective USEPA Region 9 residential PRCs and the TACO Tier I residential remediation objectives (for direct contact [i.e., ingestion and dermal contact]).

• In the laboratory, identification of MCPA in a sample can be difficult. MCPA is a poor responding compound; interferences can be very numerous, creating the problem of false positive detections (i.e., claiming a compound is present when, in actuality, it is not). The actual presence of MCPA at Site 195 is highly uncertain and the detections may be false positives. In addition, because the upper layers of soil at the site consist of concentrated, organic-rich sludge.


2-11 May 2014

it is likely that pesticide/herbicide concentrations in the soil have undergone significant biodegradation since sampling in 2001/2002.

The results of the human health risk assessment are summarized in Appendix A. In summary, the human health risks from the soil at Site 195 are acceptable for the anticipated future land users (i.e., recreational receptors and industrial and construction workers), as well as hypothetical residential receptors.

2.8.2.2 Ecological Risk Assessment Results

In the SERA, an analysis of habitat available at Site 195 found sufficient acreage and quality of habitat to support terrestrial wildlife. The ecological risk screening identified two PBT chemicals in the surface and/or shallow subsurface soil. Eight inorganics and eight organics were identified as ecoCOPCs in surface and/or shallow subsurface soil. After food-chain modeling was conducted, there were a number of factors indicating a BERA was warranted for the surface and shallow subsurface soil at Site 195.

The potential ecoCOCs identified in the BERA are those chemicals with HQs above 1 from the LOAEL-based results using the lower of 95 percent UCLs and the arithmetic means as exposure point concentrations. The potential ecoCOCs resulting from the BERA are aluminum (HQs ranging from 28 to 37 for shrews and 211 to 282 for plants), manganese (HQs ranging from 1.1 to 1.6 for plants), and MCPA (HQ of 3.1 for robins).

Despite the identification of ecologically significant resources and HQs above 1 from aluminum, manganese, and MCPA for one or more receptors, no action was justified for the following reasons:

• Aluminum is not soluble and toxic in soil with a pH of 5.5 or greater, which is present at Site 195

• Actual presence of MCPA at Site 195 is uncertain because of the analytical challenge posed by MCPA and the rapid degradation of the compound under conditions similar to those at Site 195

• HQs for terrestrial plants from manganese in the surface and shallow subsurface soil were slightly above 1, but plant vigor at the site is robust

• There are no migration pathways to more sensitive habitats.

The results of the ecological risk assessment are summarized in Table 4. Based on the results of the SERA and BERA, risks to ecological receptors at Site 195 were found to be acceptable.

Table 4. Site 195 Ecological Risk Summary Savanna Army Depot Activity, Savanna, Illinois

Area Range of Hazard Quotients

(acres) 1 and <10 10-100 >100 Rationale for Recommendation

1 Yes-Manganese and MCPA

Yes-Aluminum

Yes-Aluminum

Aluminum is not soluble and toxic in soil with a pH of 5.5 or greater, which is present at Site 195. Actual presence of MCPA at Site 195 is uncertain because of the analytical challenge posed by MCPA and the rapid degradation of the compound under conditions similar to those at Site 195. HQs for terrestrial plants from manganese in the surface and shallow subsurface soil were only slightly above 1, but the plant vigor is robust. In addition, migration pathways to more sensitive habitats are not present.

2.9 DESCRIPTION OF THE NO ACTION ALTERNATIVE

This alternative does not involve the implementation of remedial actions or land use controls to protect human health and the environment at Sites 16 and 195.


2-12 May 2014

2.10 STATUTORY DETERMINATIONS

The results of the baseline risk assessment conducted for both sites did not identify any unacceptable risks to human or ecological receptors for current or future land use scenarios. Based on these results, USEPA and the Army, in consultation with lEPA, have determined that no action is necessaiy to protect public health or welfare or the environment. Therefore, the requirements of CERCLA Section 121 including the provisions of CERCLA Section 121(d)(2) concerning ARARs are not applicable. In addition, there is no cost associated with the no action alternative. In addition, 5-year reviews are not required for the sites given the no action remedies will allow for unlimited use and unrestricted exposure.

2.11 DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for Sites 16 and 196 was released for public comment in September 2013 (SAIC 2013). No action was recommended for Sites 16 and 195. A public meeting was held at SVDA on September 25, 2013. Army, USEPA, and lEPA representatives were present at the public meeting and answered questions received from the public. No written comments were received during the public comment period. The Army reviewed all of the verbal comments and it was determined that no significant changes to the remedy, as originally identified in the Proposed Plan, were necessary or appropriate.


3. RESPONSIVENESS SUMMARY

The following responsiveness summary provides information about the community involvement and opportunities for comments during the public comment period.

3.1 BACKGROUND ON COMMUNITY INVOLVEMENT

Community relations activities conducted for Sites 16 and 195 have included the following:

• The Army placed the RI Report for the Upper Post in the Information Repository (IR) (April 2009)

• The Army placed the CL-CN Plant Area RI in the IR (April 2007)

• The Army distributed the Proposed Plan for Site 16 and 195 (September 2013)

• The Army issued multiple public notices in five area newspapers notifying the citizens of the public meeting and public comment period (September 2013)

• The Army held a public meeting at SVDA to describe the Proposed Plan and respond to citizen questions.

3.2 SUMMARY OF PUBLIC COMMENT PERIOD AND MEETING

The public comment period on the Proposed Plan for Site 16 and 195 was held from September 6 to October 6, 2013. A public meeting was held on September 25, 2013. The meeting attendee list and transcript are presented in Appendix B. Three members of the community attended the public meeting. Verbal comments received during the public meetipg were addressed as part of the meeting and are presented in the meeting transcript (Appendix B). There were no written comments received during the public comment period.


4. REFERENCES

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.

ERA (Economics Research Associates). 1997. Savanna Army Depot Reuse Plan and Implementation Strategy. Prepared for the Savanna Army Depot ERA. January.

lEPA (Illinois Environmental Protection Agency). 1980. Memorandum Regarding U.S. Ordnance -Savanna - Compliance Evaluation and O&M Survey. October 29.

lEPA. 1983. Memorandum Regarding U.S. Ordnance - Savanna - Compliance Evaluation Survey. February 5.

lEPA. 1984. Memorandum Regarding U.S. Ordnance - Savanna - Compliance Evaluation Survey. IL0027049. February 1.

lEPA. 1985. Memorandum Regarding Savanna Army Depot Activity, Wastewater Treatment Facility, Compliance Evaluation Inspection. April 1.

lEPA. 1988. Water Pollution Control Permit, Savanna Army Depot Activity, Main Treatment Plant, Land Application of Sewage Sludge. May 4.

lEPA. 2002. Tiered Approach to Corrective Action Objectives. Title 35: Environmental Protection, Subtitle G: Waste Disposal, Chapter 1: Pollution Control Board, Subchapter f; Risk Based Cleanup Objectives, Part 742. (http://www.ipcb.state.i 1.us/documents/dsweb/Get/Document-38408/

Hagerty, H. 1996. Former SVDA Employee. Personal Interview. September.

MSA (MSA Professional Services). 1999. Reuse Plan Map. Savanna Army Depot. Jo-Carroll Depot Local Redevelopment Authority, Carroll and Jo-Daviess Counties. November.

SAIC (Science Applications International Corporation). 1999. Environmental Baseline Survey Report. Final. Savanna Army Depot Activity, Savanna, Illinois. Prepared for the U.S. Army Environmental Center. May.

SAIC. 2006. No Further Action Decision Document for Sites 16S, 34, and 123. Final. Savanna Army Depot, Savanna, Illinois. September.

SAIC. 2007. CL-CN Plant Area RI. Final. Savanna Army Depot Activity, Savanna, Illinois. April.

SAIC. 2009. Remedial Investigation Report for the Upper Post. Final. Savanna Army Depot Activity, Savanna, Illinois. April.

SAIC. 2011a. Plant Area (Sites 16, 36, 47, and 84) Baseline Ecological Risk Assessment. Savanna Army Depot Activity, Savanna Illinois. Draft Final. Prepared for U.S. Army Corps of Engineers. January.

SAIC. 2011b. Sites 100 and 195 Baseline Ecological Risk Assessment. Savanna Army Depot Activity, Savanna Illinois. Final. Prepared for U.S. Army Corps of Engineers. December.

SAIC. 2012. Reuse Plan Map as revised by John Clarke (SVDA).

SAIC. 2013. Proposed Plan for Site 16 and 195. Final. Savanna Army Depot Activity, Savanna, Illinois. September.

SOD (Savanna Ordnance Depot). 1955. Historical Report, July through December 1995.


SOD. 1958. Sewer Utilities Map. January 22, 1955, revisedJanuary 1, 1958.

SOD. 1975. Unit Map 75 of Building 941. January 1945, revised through July 28, 1975.

USAGE (U.S. Army Corps of Engineers). 1999. Defense Environmental Restoration Program for Base Realignment and Closure Sites, Ordnance and Explosives Archives Search Report for Savanna Army Depot Activity. Revised Final. February.

USATHAMA (U.S. Army Toxic and Flazardous Materials Agency). 1979. Installation Assessment of Savanna Army Depot Activity, Record Evaluation Report No. 134. January.

USEPA (U.S. Environmental Protection Agency). 1977. Compliance Monitoring Field Report, Savanna Army Activity, January 12-13.

USEPA. 1987. NPDES Compliance Inspection Report. August 20.

USEPA. 1989. Federal Facility Agreement between USEPA, the State of Illinois, and the United States Army in the matter of the U.S. Department of the Army, Savanna Army Depot Activity, Savanna, Illinois. September 26.

USGS (U.S. Geological Survey). 1975. Green Island, Iowa Quadrangle, Topographic Map. November.

Westinghouse (Westinghouse Remediation Services, Inc.). 1996. Closure Report for RCRA Closure of Deactivation Furnace APE 1236. Submitted to U.S. Army Corps of Engineers, Louisville District. 29 March.


APPENDIX A

HUMAN HEALTH RISK SUMMARIES

Table A-1. Summary of Baseline Human Health Risk Assessment Results for Site 16

1 Cancer Risk | 1 Noncancer HI | Medium Exposure 1 Industrial Construction Recreational Residential 1 Industrial Construction Recreational Residential

Route Worker Worker Integrated* Integrated* | Worker Worker Child Adult Child Adult 1

Surface Soil Ingestion NA NA NA NA 3E-05 B 6E-05 B lE-04 B lE-05 B 8E-04 B 8E-05 B (0 to <0.5nBLS) Dermal Contact NA NA NA NA OE+00 B OE+00 B OE+00 B OE+00 B OE+00 B OE+00 B

inhalation of VOCs NA NA NA NA NA NA NA NA NA NA Inhalation of Dust ' NA NA NA NA NA NA NA NA NA NA Subtotal NA NA NA NA 3E-05 "B" 6E-05 B lE-04 B lE-05 "B" 8E-04 "B" 8E-05 "B

Subsurface Soil Ingestion NA NA NA NA 2E-04 B 4E-04 B NA NA 6E-03 B 6E-04 B (0.5 to 15 ft BLS) Dermal Contact NA NA NA NA OE+00 B OE+00 B NA NA OE+00 B OE+00 B

Inhalation of VOCs NA NA NA NA NA NA NA NA NA NA Inhalation of Dust NA NA NA NA NA NA NA NA NA NA Subtotal NA NA NA NA 2E-04 "B~ 4E-04 B NA NA 6E-03 "B~ 6E-04 "B

Groundwater Ingestion NA NA NA NA NA NA NA NA 2E-0I B 7E-02 B Dermal Contact NA NA NA NA NA NA NA NA 3E-04 B 2E-04 B Inhalation NA NA NA NA NA NA NA NA NA NA Subtotal NA NA NA NA NA NA NA NA 2E-0I

_ 7E-02 "B

Plant Ingestion (Surface) Leafy Vegetables NA NA NA NA NA NA NA NA lE-04 B 6E-05 B (0 to <0.5 ft BLS) Tuberous Vegetables NA NA NA NA NA NA NA NA 8E-04 B 4E-04 B

Fruits NA NA NA NA NA NA NA NA 2E-03 B IE-03 B Subtotal NA NA NA NA NA NA NA NA 3E-03 B 2E-03 "B

Plant Ingestion (Subsurface) Leafy Vegetables NA NA NA NA NA NA NA NA lE-02 B 6E-03 B (0 5 to 15 ft BLS) Tuberous Vegetables NA NA NA NA NA NA NA NA lE-02 B 6E-03 B

Fruits NA NA NA NA NA NA NA NA 3E-02 B 2E-02 _B Subtotal NA NA NA NA NA NA NA NA 5E-02 B 3E-02 "B

Surface Soil (0 to <0.5 ft BLS), Sediment, Surface Water, Groundwater, Fish, and Plant ingestion (Surface) Combined Hazard Index: Combined Cancer Risk: C I I

Subsurface Soil (O.S to 15 ft BLS), Sediment, Surface Water. Groundwater, Fish, and Plant Ingestion (Subsurface) Combined Hazard Index:

TNA I ~ Combined Cancer Risk: I I NA

NA - pathway not evaluated

Table A-2. Summary of Baseline Human Health Risk Assessment Results for Site 195

>

Canrer Risk Noncancer HI

Medium Exposure Industrial ConstructionRecreational Residential Industrial Construction Recreational Residential

Route Worker Worker Integrated* Integrated* Worker Worker Child Adult Child Adult

Surface Soil Ingestion lE-06 B lE-07 B lE-06 B 7E-(16 E 6E-02 B 6E-(I2 B 2E-01 B 2E-02 B 1E+ 00 B lE-01 B

(0 to < 0 5 ft BLS) Dermal Contact 3E-07 B 1E4>8 B lE-07 B 7E-07 B lE-02 B 4E-03 B lE-02 B 2E-03 B 8E-02 B lE-02 B

Inhalation of VOCs NA NA NA NA NA NA NA NA NA NA

Irdialation of Dust 3E-09 B 2E-08 B 8E-I0 B 5E-09 B lE-02 B 8E-01 B 5E-03 B 2E-03 B 4E-02 B 2E-02 B

Subtotal 2E-06 E 2E-07 B lE-06 B 8E4)6 E 9E-02 B 9E-01 B 2E-01 B 2E-02 B lE+00 B lE-01 B

Subsurface Soil Ingestion iE-06 B 2E-07 B NA 9E-06 E 9E-02 B 8E-02 B NA NA 2E+ 00 E 2E-01 B

(0.5 to 15 ft BLS) Dermal Contact 4E-07 B lE-08 B NA 9E-(I7 B 2E-03 B 7E-04 B NA NA lE-02 B 2E-03 B

Inhalation of VOCs NA NA NA NA NA NA NA NA NA NA

bihalation of Dust 4E-(I8 B 4E-(17 B NA 9E-0R B 9E-03 B 6E-01 B NA NA 3E-02 B 1E4I2 B

Subtotal 2E-06 E 6E-07 B NA lE-05 E IE-01 B 7E-01 B NA NA 2E+ 00 E 2E-0I B

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

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

Inhalation NA NA NA NA NA NA NA NA NA NA

Subtotal NA NA NA NA NA NA NA NA NA NA

Plant ingestion (Surface) Lealy Vegetables NA NA NA 5E-06 E NA NA NA NA 7E+ 00 E 4E+ 00 E

(0 to < 0 5 ft BLS) Tuberous Vegetables NA NA NA 6E-06 E NA NA NA NA 7E+ 00 E 4E+ 00 E

Fruits NA NA NA 4E-06 E NA NA NA NA 2E+ 00 E 1E+ 00 B

Subtotal NA NA NA 2E-05 E NA NA NA NA 2E+01 E 9E+ 00 E

Plant Ingesiion (Subsurface) LeafS' Vegetables NA NA NA 7E-06 E NA NA NA NA 5E-01 B 3E-UI B

(0.5 to 15 ft BLS) Tuberous Vegetables NA NA NA 8E-06 E NA NA NA NA 7E-01 B 4E-01 B

Fruits NA NA NA 5E-0fi E NA NA NA NA 8E-0I B 5E-01 B

Subtotal NA NA NA 2E-05 E NA NA NA NA 2E+ 00 E lE+00 B

Combined Hazard Index: 9E-02 B 1 9E-01 »l 2E-01 B 1 2E-02 B |2E+01 E llE-h 01 E

Combined Cancer Risk: 1 2E-06 E 1 2E-07 B 1 1E4)6 B 1 2E-05 E

Subsurface Soil (0.5 to IS ft BLS), Groundwater, and Plant Ingestion (Subsurface)

Combined Hazard index: lE-01 B 1 7E-0I » 1 j NA 1 NA |4E+00 E |lE+00 B

Combined Cancer Risk: 1 2E-06 E 1 6E4)7 B 1 NA 1 3E-0S E

NA - pathway not evaluated or all detected chemicals eliminated as COPCs 0E+ 00 - pathway evaluated but no risks could be calculated due to lack of EPA-approved toxicii> values

' integrated receptor combines both child and adult exposures

B-H1< I orELCR< lO-* E-HI>1orELCR>1Q-®

Table A-3. Lead Model Output for Resident Children at Site 16 - Surface Soil Savanna Army Depot, Savanna, Illinois

lEUBK Windows Version 1.0

Model Version; 1.0 User Name: Date: Site Name; Operable Unit; Run Mode; Research

The Time Step Used in This Model Run; 1 - Eveiy 4 hours (6 times a day).

Indoor Air Pb Concentration; 30.000 percent of outdoor. Other Air Parameters;

Age Time Ventilation Lung Outdoor Air Outdoors Rate Absorption Pb Cone (hours) (m'^3/day) (%) pg Pb/m'^3

.5-1 1.000 2.000 32.000 0.100 1-2 2.000 3.000 32.000 0.100 2-3 3.000 5.000 32.000 0.100 3-4 4.000 5.000 32.000 0.100 4-5 4.000 5.000 32.000 0.100 5-6 4.000 7.000 32.000 0.100 6-7 4.000 7.000 32.000 0.100

Age Diet Intake (pg/day) .5-1 5.530 1-2 5.780 2-3 6.490 3-4 6.240 4-5 6.010 5-6 6.340 6-7 7.000

• •••••Drinking Water******

Water Consumption; Age Water (L/day) .5-1 0.200 1-2 0.500 2-3 0.520 3-4 0.530 4-5 0.550 5-6 0.580 6-7 0.590 Drinking Water Concentration; 4.000 pg Pb/L

******Soil& Dust******

Multiple Source Analysis Used Average Multiple Source Concentration; 80.700 pg/g

A-3

Table A-3. Lead Model Output for Resident Children at Site 16 - Surface Soil Savanna Army Depot, Savanna, Illinois (Continued)

Mass Fraction of Outdoor Soil to Indoor Dust Conversion Factor: 0.700 Outdoor Airborne Lead to Indoor Household Dust Lead Concentration: 100.000 Use alternate indoor dust Pb sources? No Age Soil (ng Pb/g) House Dust (gg Pb/g) .5-1 101.000 80.700 1-2 101.000 80.700 2-3 101.000 80.700 3-4 101.000 80.700 4-5 101.000 80.700 5-6 101.000 80.700 6-7 101.000 80.700

******Altemate Intake******

Age Alternate (gg Pb/day) .5-1 0.000 1-2 0.000 2-3 0.000 3-4 0.000 4-5 0.000 5-6 0.000 6-7 0.000

******Matemal Contribution: Infant Model******

Maternal Blood Concentration: .500 gg Pb/dL

tttt-ttt*************** ******* *******

CALCULATED BLOOD LEAD AND LEAD UPTAKES:

************************************ Year Air Diet Alternate Water

(gg/dL) (gg/day) (gg/day) (gg/day)

5-1 0.021 2.608 0.000 0.377 1-2 0.034 2.716 0.000 0.940 2-3 0.062 3.069 0.000 0.984 3-4 0.067 2.976 0.000 1.011 4-5 0.067 2.899 0.000 1.061 5-6 0.093 3.071 0.000 1.124 6-7 0.093 3.396 0.000 1.145

Year SoiH-Dust Total Blood (gg/day) (gg/day) (pg/dL)

.5-1 2.160 5.167 2.8 1-2 3.420 7.110 3.0 2-3 3.441 7.556 2.8 3-4 3.470 7.524 2.7 4-5 2.600 6.627 2.3 5-6 2.350 6.638 2.1 6-7 2.223 6.858 1.9

A-4

Table A-4. Blood Lead Levels of Fetus of Industrial Workers (Surface Soil Exposure) SVDA Lower Post Rl

Exposure Unit

M.anPb BKSF (T.rg«=10 Mg/bL|

Cone. (uglOLpor IRi AF, EF. AT FbB„.i«.„i OSDi,.j.i, FbB™.„ (mg/kg) (pg/dL) ug/day) (g/day) (unitless) (day/yr) (day/yr) (ufl/dL) (unitless) (unitless) (ug/dL) Conclusion

Site 16-Small Arms Ammunition Deactivation Furnace 101 1.72 0.4 0.05 0.12 219 365 1.9 1.90 0.9 4.8 below target

> cn

- Not applicable/not evaluated

PbBaduii.o and GSDi.aduit values were calculated based on county census data. Model default values were used for all other parameters (except the site lead concentration). PbBaduR,o - Baseline blood lead level BKSF - bioklnetic slope factor

IRs - Ingestion rate

AF - adherence factor

EF - exposure frequency

AT - averaging time

PhBaduncantrai - mean blood lead level

GSD - geometric standard deviation

RfBtai/maiBmai - factor that convorts blood lead level In mother to blood lead level In fetus

PbBfetai,o.95 - mean blood lead level In fetus at 95th percentile

Table A-5. Blood Lead Levels of Residential Children (Surface Soil Exposure) SVDA Lower Post Rl

Exposure Unit

Mean Lead Concentration

in Soii' (mg/ka)

Geometric Standard Deviation (unitless)

Geometric Mean Biood Lead Level*'

(Mg/dL)

Mean Blood Lead Level at

95th Percentile (Target=10 pg/dL)

Percent Exceeding

10 ng Pb/dL" Conclusion

Site 16 - Small Arms Ammunition Deactivation Furnace 101 1.6 2,519 5.5 0.151 below target

®Site-specific lead concentration - arithmetic mean used in the model. "USEPA's LEAD lEUBKwin model was used to project blood lead levels for ages 6-84 months. The benchmark set by the Centers for Disease Control and Prevention specifies that 95% of the blood lead levels in the sensitive population must not exceed 10 pg/dL ~ Not appiicabie

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APPENDIX B

PUBLIC MEETING SIGN-IN SHEET AND PUBLIC MEETING TRANSCRIPT

PUBLIC MEETING SIGN-IN SHEET

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Savanna Army Depot Activity September 25,2013

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PUBLIC MEETING TRANSCRIPT

B-3

SAVANNA ARMY DEPOT ACTIVITY

PROPOSED PLAN FOR SITE 16 and PROPOSED PLAN FOR SITE 195

In the Matter of the ) Savanna Army Depot September 25, 2013 ) Savanna, Illinois Public Meeting 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 Vasu Peterson Jamie Johnson Mike Barta

Present on behalf of USACE: Todd Knuth Nora Hawk

Present on behalf of RAB: Terrence Ingram

Others Present: Jo Carey Craig Hoby Art Dersham Emmett Engel Alan Anderson

Cathy Collins, Base Realignment and Closure Environmental Coordinator

Court Reporter: Julie K. Edeus, CSR

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B-4

1 MS. COLLINS: Okay. 6 o'clock. I'm Kathy

2 Collins. I'm the BRAC Environmental Coordinator

3 at the Savanna Army Depot. We're having a

4 Proposed Plan Meeting for Sites 16 and 195.

5 The purpose of the Proposed Plan is to

6 encourage public participation in the remedy

7 selection process and to ensure that the

8 statutory requirements of the Comprehensive

9 Environmental Response Compensation and

10 Liability Act (CERCLA), Section 117(a) are

11 fulfilled.

12 The Proposed Plan summarizes the cleanup

13 or no further action alternatives evaluated in

14 the respective Remedial Investigation

15 Feasibility Study -- abbreviated RIPS --

16 performed on each site and identify the proposed

17 -- the preferred remedy.

18 Various RIFS reports are referenced in the

19 Proposed Plans and are available for public

20 review in the Hanover and Savanna Public

21 Libraries.

22 As part of the process required by CERCLA,

23 the Army established a 30-day comment period for

24 these two sites. The period began on 6 -- 6

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B-5 In Totidem Verbis, LLC (ITV)

1 September and ends 6 October of 2013. Written

2 comments postmarked before midnight on that date

3 will be considered. After evaluating all of the

4 written comments submitted by the public, the

5 Army, in conjunction with the USEPA and the

6 Illinois EPA, will finalize the proposed

7 alternative into a record of decision or select

8 another remedy based upon new information or on

9 the comments received from the public.

10 I will now turn the time over to Ms. Marcy

11 Larriva of the SAIC Corporation to present the

12 Proposed Plans.

13 MS. LARRIVA: I want to welcome everyone

14 to the public meeting for Sites 16 and 195. As

15 Kathy mentioned, today we've got representatives

16 from USEPA, lEPA and the Army and SAIC. I'm

17 Marcy Larriva. I'm the project manager at SAIC

18 that's been doing the RIFS work out here at

19 Savanna at each particular site. Also, we got

20 Linda Meredith, our human health risk assessor

21 and Mike Barta, our ecological risk assessor

22 that will be presenting the information from

23 this Proposed Plan today.

24 Basically the purpose of this meeting is

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1 to summarize the environmental investigations,

2 the work that's been conducted at the site, one

3 of which has had some remedial action and then

4 we're going to present the remedial

5 investigation results and proposed

6 recommendation for these two sites. These

7 recommendations have been agreed to based on

8 work developed by the Army, USEPA and lEPA. And

9 we're encouraging the public to participate and

10 provide comments on the site recommendations.

11 As Kathy mentioned, the site -- the

12 background on why this proposed plan is

13 necessary is because in 1980 Congress enacted a

14 law known as the Comprehensive Environmental

15 Response Compensation and Liability Act or

16 CERCLA. And the law puts into place the

17 processes for addressing closed and abandoned

18 hazardous waste sites that could potentially

19 endanger human health or the environment.

20 Savanna was placed on the National

21 Priority List back in 1989 and we're following

22 that process to get through these sites and the

23 closure.

24 This kind of gives an overview of the

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1 CERCLA process. It's a long-term process to go

2 through and it identifies the hazards in certain

3 areas. It starts with the pre-remedial response

4 process where they conduct a preliminary

5 assessment, they go through and do some site

6 inspection. And at that point they did place

7 Savanna on the NPL list. Based on what came out

8 of that information, we started the remedial

9 investigation or RIFS process. We would go

10 through to the different sites and try to

11 identify if there was contamination present at

12 any of these sites and this is the general

13 process. If some sort of contamination was

14 identified, then it would go into a feasibility

15 study to evaluate alternatives for potential

16 cleanup, if necessary. Once it's gone through

17 the RIFS process, it would then get into a

18 Proposed Plan for choosing a remedy for the site

19 and that's the stage we're at for these two

20 sites is the Proposed Plan. Once we get the

21 comments in on this Proposed Plan, we'll

22 evaluate them, respond to them as necessary and

23 then everything will be recorded in a record of

24 decision or a ROD.

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1 Just some background on Savanna. Savanna

2 Army Depot was established in 1917 as a proving

3 and testing facility for weapons developed down

4 at Rock Island Arsenal. In 1918 it became an

5 ordnance depot. And then in 1939 construction

6 of additional magazines, buildings and bomb and

7 shell loading plants were initiated here at

8 Savanna.

9 In 1995 Savanna was selected for closure

10 under the Base Realignment and Closure Act or

11 the BRAG Act. And in 2000 Savanna was

12 officially closed.

13 Current army activities here at Savanna

14 are to assess and clean up contamination and

15 transfer property on the site.

16 This gives an idea of the land transfer.

17 Just a general picture of how much of the land

18 is going and slated for different reuses. As

19 you can see, Fish and Wildlife is getting the

20 majority of the property here at Savanna and the

21 rest -- which is about 76 percent. About 21

22 percent is LRA and there's a little bit going to

23 the Corps of Engineers and the IDNR.

24 For the sites presented in this Proposed

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1 Plan, Site 16 is going in that LRA parcel, so

2 it's industrial/commercial reuse. Site 195 is

3 going to Fish and Wildlife Service.

4 The two sites being presented in this

5 Proposed Plan are Site 16, which is the Small

6 Arms Deactivation Furnace and Site 195, which is

7 a Wildlife Sludge Application Area. This is --

8 kind of shows where they're located. It's

9 really hard to see on this map. There is

10 another map over there. But basically the

11 deactivation furnace is all the way on the

12 southern end down in the plant area here in

13 Savanna. And the wildlife area is all the way

14 in the northern portion of the installation.

15 Just as kind of a background for

16 environmental investigations that have been

17 conducted here and at other sites at Savanna,

18 what we tend to do is we start out with an

19 analysis of historical information to try and

20 determine where there might be potential

21 contamination at the site. We look at aerial

22 photographs, interviews with former employees

23 that are familiar with the site, as well as any

24 kind of historical documentation and maps that

(815) 453-2260


1 we can find.

2 We do a phased approach for the

3 environmental sampling. The Phase 1 is

4 basically targeting the most likely areas of

5 contamination. And for a chemical release, the

6 analytes lists are specific to the historical

7 background of what we might expect.

8 Subsequent phases, we go out to do

9 delineation in trying to determine if there's

10 any type of migration within those areas. The

11 sites being presented here, 16 and 195, had

12 minimum of at least two phases of sampling

13 conducted. Once we get the chemical data back

14 from that sampling, we move forward with

15 determining if there's any potential harm to

16 human health or the environment.

17 The first site is the Small Arms

18 Deactivation Furnace. The plant was built in

19 1961 and was used until about 1995. It was used

20 to thermally treat small arms ammunition and

21 reactive wastes which would include explosive

22 mixtures and propellant mixtures. It was -- the

23 site was closed in 1995 as part of the Resource

24 Conservation and Recovery Act or a RCRA closure.

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B-11

In Totidem Verbis, LLC (ITV)

1 and they did conduct cleanup out there for

2 (TCLP) lead in soil and they had a targeted area

3 where they did sampling. That sampling didn't

4 focus as much on the typical human health and

5 ecological risk assessments, so SAIC started

6 doing sampling out there in the '99/2000 time

7 frame. We went out and did soil sampling

8 outside of the excavation area to ensure that

9 there was no remaining concentrations beyond the

10 recorded cleanup area. In addition to that we

11 installed groundwater monitoring wells across

12 the site to ensure that the groundwater had not

13 been impacted by site activities. Based on

14 those levels we did detect some metals in the

15 soil and groundwater out there. The groundwater

16 I believe was all at background levels. There

17 was no concern for groundwater.

18 The next area is the Wildlife Sludge

19 Application Area. This area was one of four

20 areas where it was used here at Savanna. They

21 would land apply the sanitary sludge from the

22 main sewage treatment plant that's located down

23 here in lower post. Basically the sludge

24 generated from the plant was spread over the

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1 surface of these areas once a year between 1988

2 through 1996. There was one year in there that

3 they did not apply sludge. Between 1999 and

4 2002 SAIC went out and did some sampling out

5 there. We analyzed the soils for SVOCs, PCBs,

6 metals, pesticides and herbicides to determine

7 if anything had been released during those

8 applications that were done. We collected soil

9 samples over the area. We had semivolatile

10 organic compounds, metals, pesticides and

11 herbicides all detected in the soil out there.

12 That basically is an overview of the

13 sampling that was done at these two sites and a

14 little bit of the site history. I'm now going

15 to turn things over to Linda Meredith so that

16 she can present to you guys the overview of the

17 risk assessment that was conducted in order to

18 determine if there was any potential harm for

19 humans or the environment. Linda.

20 MR. INGRAM: I have a question first.

21 Site 195, is that subject to flooding?

22 MS. LARRIVA: No. It's on the other side

23 of the base. It's pretty high up.

24 MR. INGRAM: Because I know the river

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B-13


1 comes up pretty high in that area.

2 MS. LARRIVA: Yeah, this is further --

3 it's on the eastern boundary.

4 MR. INGRAM: I know where it is.

5 MS. LARRIVA: Okay. No, there hasn't been

6 any sign of flooding up in that area.

7 MR. INGRAM: Okay. Because the flooding

8 gets up as high as the railroad tracks.

9 MS. LARRIVA: We haven't seen any sign of

10 flooding up in that -- at the site before.

11 MR. INGRAM: Okay. Just wondering.

12 MS. LARRIVA: Uh-huh.

13 MS. MEREDITH: I'm going to begin with a

14 brief overview of the risk assessment process.

15 Two types of risk assessment were

16 conducted at these sites, human health and

17 ecological risk assessments. The overall

18 process is the same. The human health risk

19 assessment focuses on risks to people and in an

20 ecological risk assessment we focus on risk to

21 wildlife.

22 We follow a four-step process, which is

23 shown up here on the overhead. In the first

24 step, the data evaluation, we collect

(815) 453-2260


1 environmental samples. And the results of these

2 samples help us determine if we have

3 contamination present at the site and if so, at

4 what concentrations do we have chemicals that

5 were detected.

6 In the second step, the exposure

7 assessment, we look at who may be exposed -- who

8 or what may be exposed to chemicals at the site.

9 For example, do we have people that come to the

10 site, do we have wildlife that visit the site,

11 how often might they come to the site, how long

12 might they stay there. These are some of the

13 questions that we answer in the exposure

14 assessment.

15 In the third step, the toxicity

16 assessment, we evaluate if the chemicals that

17 we've detected are dangerous to people or

18 wildlife and if so, how and in what quantities.

19 And in the last step, the risk

20 characterization, this is where we sort of

21 integrate the results of the previous steps. We

22 look at the chemicals detected, the results of

23 the exposure assessment and whether or not

24 they're toxic and that's how we determine risks

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B-15 In Totidem Verbis. LLC (ITV)

1 to humans and wildlife.

2 In the exposure assessment -- so -- again,

3 that was something that was general to both

4 human health and eco. Now I'm going to talk

5 specifically about the human health risk

6 assessment.

7 In the human health exposure assessment we

8 looked at what the planned future land use is

9 for these two sites and who might be exposed.

10 Marcy mentioned earlier that Site 16 is part of

11 that parcel that's going to the LRA. The

12 planned future land use is industrial. And so

13 we evaluated industrial/commercial workers and

14 we also evaluated construction workers. The

15 difference here is that construction workers, as

16 you might expect, are -- they experience greater

17 exposure, they're typically more, you know,

18 exposed to soil and other environmental media.

19 At Site 195 our planned future land use is

20 recreational. So here we evaluated recreational

21 visitors such as children and adults. And then

22 also we also looked at workers. We could have

23 workers involved in maintaining the property,

24 perhaps involved in education. And then at both

(815) 453-2260


1 sites we evaluated a residential land use

2 scenario. This is a hypothetical scenario.

3 It's unlikely according to our reuse plan. And

4 under this scenario we evaluated resident

5 children and adults.

6 In the data collection or the data

7 collection evaluation step, again, this sort of

8 assesses what data we evaluated or calculated

9 risks on. And here this is essentially a

10 summary of what Marcy went over earlier. We

11 collected soil and groundwater samples. This

12 was after the removal action was completed that

13 was associated with the RCRA closure and metals

14 were detected and most of those were at

15 background concentrations.

16 And then at Site 195 we collected soil

17 samples and we had semivolatile organic

18 compounds, metals, pesticides and herbicides

19 that were detected in the soil.

20 In the toxicity assessment we used

21 published values that help us detect if

22 chemicals are toxic to humans. Those are values

23 that are -- typically the values we use are

24 USEPA published values. Sometimes we use values

(815) 453-2260


1 from ATSDR or California EPA or other agencies.

2 The risk characterization of the risk

3 assessment. We look at both cancer and

4 noncancer effects. And we look at those risks

5 and we compare them to regulatory targets. And

6 our targets for the cancer risks, it's a cancer

7 risk range of 10 to the negative 6 to 10 to the

8 negative 4. And for noncancer effects the

9 target HI is 1.

10 And so this is a summary of the human

11 health risk assessment for these two sites. At

12 Site 16 our human health risks are acceptable.

13 That means they met our targets for cancer and

14 noncancer effects and no further action was

15 recommended for Site 16.

16 At Site 195 we also had -- our conclusions

17 were the same. Our human health risks met our

18 regulatory targets and no action is recommended.

19 More specifically at Site 195, for our planned

20 future land use we had risks that were within

21 our range and our target HI is below 1.

22 However, for our unrestricted residential land

23 use, we did have an exceedance, our HI exceeded

24 our target of 1. However, the exceedances were

(815) 453-2260


1 due to a hypothetical produce ingestion pathway.

2 These risks are considered conservative due to

3 conservative assumptions that are used in the

4 risk assessment. And also the max

5 concentrations of those chemicals that were

6 responsible for the exceedance of the HI, they

7 are less than the -- those max concentrations

8 are less than the lEPA screening levels for

9 residential soil. And so this supported our

10 recommendation of no further action for Site

11 195.

12 And that's essentially a summary of the

13 human health risks at Site 16 and 195. And now

14 I'm going to turn it over to Mike and you can

15 talk about the ecological risks.

16 MR. INGRAM: Question.

17 MS. MEREDITH: Sure.

18 MR. INGRAM: What provisions are in there

19 for those risk levels to change in the future

20 for --my brother used to be in atomic physics

21 and he was in charge of an accelerator down at

22 the University of Iowa and had to wear a badge

23 all the time and know what radiation he got.

24 One day he came to work and he couldn't go to

(815) 453-2260


1 work anymore. He had received the radiation --

2 they had lowered the amount of radiation a

3 person can get in his lifetime and he already

4 exceeded that. What happens if we lower some of

5 these levels? Do we have any way of going back

6 and checking or doing something more with them?

7 MS. MEREDITH: Well, cancer risks are

8 calculated over a lifetime, so it's a 70-year

9 lifetime. So it does look at risks at the

10 current levels that we've detected in the soil

11 --it looks at risks over a lifetime. It

12 doesn't take into account, for example, if you

13 would have new contamination that was introduced

14 or if you would have degradation of the

15 chemicals where maybe your concentrations would

16 decrease. So -- sorry.

17 MR. INGRAM: Let's say the levels for

18 aluminum, lead, mercury, are those that chemical

19 itself or is it a combination of that chemical

20 and mercury and lead, the three of them?

21 Because DDT -- DDT used to be very sensitive and

22 then they found out that if DDT is combined with

23 some other insecticide, the sensitivity drops

24 way down and in a much lower amount will create

(815) 453-2260


1 the same or greater risk.

2 MS. MEREDITH; Right. We do look at risks

3 --it's additive risks from all the chemicals.

4 So it's not just a risk associated with a single

5 chemical. For cancer risks the effects are

6 additive. So we are looking at the total cancer

7 risks from all the chemicals that were detected

8 at the site.

9 MR. INGRAM: Okay.

10 MR. BARTA: An ecological risk assessment

11 examines the potential for adverse effects to

12 wildlife.

13 The first step in the process is to

14 evaluate the habitat. And there we determine if

15 we have adequate habitat, quality and quantity.

16 The second step we determine if we have

17 chemicals that might move up through the food

18 chain; for instance, mercury, PCBs, pesticides

19 like DDT.

20 In the next step we compare the site

21 concentrations to protective concentrations such

22 as USEPA Region 5 screening levels. And for

23 those chemicals that are detected at levels

24 above their protective concentrations, we then

(815) 453-2260


1 move them into the final step where we estimate

2 the amount of the chemical that the wildlife

3 will consume and we compare that to toxic levels

4 to determine our potential for adverse effects.

5 The receptors we evaluated at both of

6 these sites included terrestrial plants, robins,

7 short-tailed shrew, red-tailed hawks and bald

8 eagles. And the pathways -- exposure pathways

9 that we evaluated included direct contact to the

10 plants, soil ingestion for the wildlife and food

11 ingestion for the wildlife as well. We did not

12 evaluate surface water ingestion because there's

13 no surface water at these two sites.

14 Next slide. Both of these sites were

15 evaluated in a screening level ecological risk

16 assessment. And this is a very conservative

17 evaluation where we're trying to determine if no

18 action is appropriate or if we need further

19 evaluation in a baseline ecological risk

20 assessment.

21 For these two sites SERA recommended that

22 we go on to a baseline ecological risk

23 assessment. The baseline eco risk assessment is

24 a more realistic evaluation where we determine

(815) 453-2260


1 whether we need to evaluate a chemical or

2 multiple chemicals in a feasibility study for

3 remediation or whether no further action is

4 appropriate.

5 Next slide. Site 16 BERA results. There

6 was adequate habitat quality and quantity at

7 Site 16, but the concentrations were determined

8 not to be harmful to wildlife and no further

9 action was recommended. Some of the supporting

10 rationale for the no further action

11 recommendation included we didn't have any risk

12 predicted for wildlife, we had very limited risk

13 predicted for plants from lead; however, at this

14 site we have two state-endangered plants, James'

15 Clammy-weed and the False Heather and they're

16 both growing at the site despite the risk

17 prediction. The soils have also previously been

18 remediated at Site 16. About 3.6 acres, which

19 is about 30 percent of the site, was remediated

20 back in the '90s.

21 Next slide. Similar results at Site 195.

22 There was existing habitat quality and quantity,

23 but the concentrations were deemed not to be

24 harmful to wildlife and required no action.

(815) 453-2260


1 Some of the supporting rationale for the no

2 action included for aluminum, while we had some

3 risk predicted, the metal is not soluble and

4 toxic at the PH that's present at the site. So

5 it's there, but it's not toxic. We also had

6 some very limited plant risk predicted for

7 manganese, but if you've been to the site, the

8 plant growth is fairly robust. And we also

9 didn't have any migration pathways to more

10 sensitive environments.

11 I can take eco questions now or we'll have

12 general questions in about three slides. It's

13 your --

14 MR. INGRAM: Go to the general questions.

15 MR. BARTA: Okay. So in conclusion, no

16 action is recommended at Sites 16 and 195 based

17 on the environmental investigations and the risk

18 assessments. US Army, USEPA and Illinois EPA

19 are in agreement with the recommendations for

20 these sites.

21 As Kathy mentioned earlier, the public

22 comment period, September 6 -- it's already

23 started -- through October 6. As long as you

24 submit your comments by midnight October 6, they

(815) 453-2260


1 will be considered -- reviewed and considered

2 and then the final decisions will be documented

3 in the record of decision, also known as the

4 ROD. And if you have questions, comments or

5 suggestions, please send them to Kathy,

6 MR. INGRAM: Question. Something that Tom

7 and Charlene know, I question -- always question

8 this. What studies have been done of what

9 birds, animals out here?

10 MR. BARTA: We haven't done any specific

11 studies on birds. At some of the sites, for

12 instance. Site 178, we did collect fish tissues

13 there.

14 MR. INGRAM: I mean these two.

15 MR. BARTA: At these two sites we only

16 collected chemical data. There were no

17 biological studies. You know, we've evaluated

18 hundreds of sites at Savanna --

19 MR. INGRAM: You say the habitat is good.

20 Good for what?

21 MR. BARTA: Well, that's a qualitative

22 judgment. You know, for instance, we would deem

23 that the habitat quality isn't that good at some

24 of the lower post sites because they may have

(815) 453-2260

B-25


1 just a very small strip of grass or they may be

2 all concrete. You know, at Site 16 you do have

3 a building there, but it is surrounded by

4 vegetation. And Site 195 is all vegetation.

5 MS. FALCO: Terry, the habitat evaluation

6 was -- we -- we didn't end up using that for

7 anything one way or another. You know, it was

8 initially designed to look at some of the more

9 industrial sites and if it was a building

10 surrounded by blacktop, we were like, well, we

11 maybe don't have to do an ecological risk

12 assessment here. So that was kind of the

13 purpose of it. We ended up -- you know, any

14 site that's in -- that's not in the lower post,

15 upper post or whatever, has, you know,

16 sufficient habitat to do an assessment and so it

17 was never really an important part of this.

18 MR. INGRAM: I was wondering about 195.

19 It has the potential -- great potential for a

20 great variety of birds and we've been able to

21 prove by bird banding that there is certain

22 birds, when they're migrating through, they'll

23 stop and stay there for a week or so and feed up

24 -- fatten up and move on. And if they come into

(815) 453-2260


1 this area and fatten up on some insects that

2 have contamination in them, will they get enough

3 of that contamination built up in their system

4 to affect them moving on? That's what I'm

5 trying to get a handle on.

6 MS. FALCO: Is that the type of thing that

7 an assessment for the robin would capture or --

8 MR. BARTA: You'd actually have to go on

9 and do some survey work. You know, I don't

10 think some of the chemicals there would have

11 potential to move up through the food chain and

12 some of the herbicides tend to degrade in a

13 shorter period of time.

14 MR. INGRAM: Some of them don't like

15 Roundup.

16 MR. BARTA: Some of them don't. The food

17 chain models do incorporate accumulation, so we

18 take that into account. It's just based on

19 values from the literature rather than

20 site-specific studies.

21 MR. INGRAM: Because I'd like to know more

22 specifically what -- what birds might be using

23 that area, what might be affected by -- what if

24 they do stop there for a week, I mean, they're

(815) 453-2260


1 not birds that live there, they're birds that

2 stop there and feed and fatten up on their way

3 moving south or north just like the Sandhill

4 cranes stop in Nebraska. A half million of them

5 stop there, they stay there for two or three

6 weeks and then they move on. But while -- that

7 two or three weeks they're there, they're

8 filling up on the corn and other insects, grubs

9 and so forth that they find and I'm just worried

10 about some of these things being contaminated

11 enough that they could get an accumulated amount

12 of chemicals in their system to affect them

13 later on. That's what I'm -- you know, I know

14 we've seen this. I've been on these guys

15 constantly, but that's one thing I'm concerned

16 about is the damage you might be doing to some

17 of the birds and animals that aren't there for a

18 great length of time.

19 MR. BARTA: The receptors that we

20 selected, the shrew, for instance, and the

21 robin, are typically more conservative than some

22 of the other bird species that would feed there.

23 MR. INGRAM: But are they actually living

24 in that habitat?

(815) 453-2260


1 MR. BARTA: Well, some of them may be.

2 You know, we have to use a model. There's so

3 many sites at Savanna that we can't evaluate the

4 specific species at each site, but we think the

5 models are conservative enough that we would

6 capture that issue if it was occurring.

7 MR. INGRAM: Well, there's going to be

8 habitat here for this bird, there's going to be

9 habitat here for this bird and habitat here for

10 this bird -- this specie I'm talking about and

11 each of these areas may have a unique habitat

12 for a certain species and we may be affecting

13 that specie without knowing it and choosing

14 these four specimens -- like the bald eagle I

15 think is stupid, even though that's the bird I

16 fight for, but having that as a sample -- the

17 bald eagle is not --as far as I'm concerned not

18 going to be affected by anything out here except

19 for the fish --the mercury in the fish when they

20 eat enough fish out in the river, but as far as

21 eating enough animals out here, I don't think

22 the bald eagle would be -- but there's other --

23 many other things that I think we have to be

24 worried about and I'm worried about all of

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1 these. We're losing our habitat to the big

2 corporate farmers. They're cutting down our

3 fence rows and cutting down our waterways and

4 the birds and -- they don't have any place to go

5 anymore and we're squeezing them into a unique

6 area and we may be squeezing them into an area

7 that's already contaminated with some of these

8 chemicals. That's what I'm worried about. And

9 I think we got to keep our eye open for that

10 possibility. You see what I'm saying?

11 MR. BARTA: I see what you're saying.

12 Other questions? General questions?

13 MR. INGRAM: Aluminum you said was -- that

14 was one of the ones the amount was too high?

15 MR. BARTA: We had elevated

16 concentrations. We predicted some risks, but

17 the model is conservative and it doesn't account

18 for the fact that aluminum is not soluble and

19 toxic above a certain PH and we have PHs above

20 that threshold, so we wouldn't expect to see any

21 toxicity to animals.

22 MR. INGRAM: What's the PH at that site

23 195?

24 MR. BARTA: It's about 5.98 in surface

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1 soil and the threshold is 5.5. And I believe

2 the toxicity --or the PH in the subsurface soil

3 is around 6.25.

4 MR. INGRAM: Doesn't that vary according

5 to whether some of the trees are out in the

6 open?

7 MR. BARTA: It certainly can.

8 MR. INGRAM: What might be in there to

9 make it -- creating the PH?

10 MR. BARTA: I'm not a soil scientist, but

11 it can certainly vary. That's the data that we

12 have. And typically at Savanna -- Marcy, you

13 can correct me if I'm wrong --we usually see PH

14 readings above 5.5 --

15 MS. LARRIVA: Yes.

16 MR. BARTA: -- at most of the sites.

17 MR. INGRAM: But here we're talking about

18 this site. I want to know what information we

19 have on this site.

20 MS. LARRIVA: And that's the information

21 we have on this site.

22 MR. INGRAM: We're here to do something

23 with this site and I want to see the -- you

24 know, what the information is on this site, not

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1 in general.

2 MR. BARTA: 5.98.

3 MR. INGRAM: There's a general 13,000

4 acres, but we're talking about a particular site

5 here and it doesn't tell me exactly how many

6 acres this site was.

7 MR. BARTA: I believe that's 1 acre --

8 Site 195.

9 MS. LARRIVA: It's pretty small.

10 MR. INGRAM: That's what 1 was trying to

11 find. 1 may have missed it, but 1 couldn't find

12 it and the same way with the next one we get to.

13 I'm just worried about us jumping in to walk

14 away from these areas and they might still

15 contain some future contamination that would

16 affect our wildlife.

17 MS. FALCO: It's fairly typical that, you

18 know, we'll take one or two PH samples for a

19 site and you know, not take, you know,

20 multitudes of PH samples, so you know, 1 think

21 the level of effort for PH at the site was

22 customary and usual.

23 MR. INGRAM: But aluminum -- you made the

24 statement aluminum doesn't move if it's a high

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0

1 PH, so I was just wondering if there were

2 certain areas in there where the aluminum would

3 move. That's what I'm trying to understand.

4 I'm worried about it getting into the insects

5 and moving up into the food chain, not the

6 robins, but the flycatchers and the warblers and

7 other things that stop there for a few days and

8 feed on those insects that are in those plants

9 or trees.

10 MS. COLLINS: Would there be like a

11 dilution effect though as it moves up the food

12 chain or --

13 MR. INGRAM: Maybe a concentration.

14 MR. BARTA: Aluminum is not a known

15 bioaccumulator like mercury, so the movement up

16 the food chain is probably going to be fairly

17 limited even if you had PHs --

18 MR. INGRAM: Isn't lead accumulative?

19 MR. BARTA: More so than aluminum, but not

20 as much as, say, mercury.

21 MR. INGRAM: Oh.

22 MR. BARTA: I can assure you though that

23 the lEPA and USEPA drill us on all these sites.

24 MR. INGRAM: I know. I'm on them all the

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1 time.

2 MR. BARTA: Other questions on Sites 16

3 and 195? Okay.

4 MR. INGRAM: If I was going to be Alan --

5 what's your thought, Alan?

6 MR. ANDERSON: I only got one thing and

7 it's not even about your work here. I just

8 wanted to say that tomorrow is the tenth

9 anniversary of Lost Mound being established as

10 part of the National Wildlife Refuge System,

11 so --

12 MS. CAREY: Are you serving cake?

13 MR. ANDERSON: It's road kill, but --

14 MR. INGRAM: Skunk or possum?

15 MS. LARRIVA: Well, that's all we have.

16 We thank you for your time.

17 MR. SMITH: When does the public comment

18 period close?

19 MS. LARRIVA: October 6th.

20 MR. SMITH: Thank you.

21 (The public meeting was concluded

22 at 6:36 p.m.)

23

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B"34 In Totidem Verbis, LLC (ITV)

1 CERTIFICATE

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 20th day of

10 September 2013.

11

12

13 Julie K. Edeus

14 Certified Shorthand Reporter IL License No. 084-003820

15 P.O. Box 381 Dixon, Illinois 61021

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(815) 453-2260

B 35 In Totidem Verbis, LLC (ITV)

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