INAAP corrective measures study for burning ground area sites 26, 27, 28, 34, 46, 56, 59, 60 report Oct 2003
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The final report of corrective measures study for burning ground area sites 26, 27, 28, 34, 46, 56, 59, and 60 at Indiana Army Ammunition Plant prepared for U.S. Army Corps of Engineers in October 2003.The United States federal government began acquiring land in Charlestown, Indiana in 1940 to build a smokeless powder ordnance plant to supply the US military during World War II. Indiana Ordnance Works (IOW) Plant 1 and Hoosier Ordnance Plant (HOP) began production in 1941. In 1944, IOW Plant 2 construction began. On 30 Nov 1945 at the end of WWII, the three plants were combined and renamed Indiana Arsenal. Between 1 Nov 1961 and 1 Aug 1963, the plant was designated Indiana Ordnance Plant. After this time, it became Indiana Army Ammunition Plant (INAAP). Production of ordnance continued at the plant until 1992. After that time, the land and facilities were leased to private industry. A large portion of the land became Charlestown State Park. In October 2016, all the land and facilities were officially sold by the government. This item is part of a larger collection of items from INAAP that are kept at Charlestown Library. FINAL REPORTCORRECTIVE MEASURES STUDYFOR BURNING GROUND AREA –SITES 26, 27, 28, 34, 46, 56, 59, 60INDIANA ARMY AMMUNITION PLANTPrepared forU.S. Army Corps of EngineersLouisville DistrictOctober 2003Prepared byURS 12120 Shamrock Plaza, Suite 300Omaha, Nebraska 68154TABLE OF CONTENTSQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA iExecutive Summary ..........................................................................................................................ES-1Section 1 Project Background....................................................................................................... 1-11.1 Purpose and Scope of Corrective Measures Study .................................. 1-11.2 Environmental Status ............................................................................... 1-11.3 Site History .............................................................................................. 1-21.3.1 Old Trash Burning Area - Site 26 ................................................ 1-21.3.2 Lead Storage Building 714-5 - Site 27 ........................................ 1-21.3.3 Drainage Area Dumping Ground - Site 28 .................................. 1-31.3.4 Trash Incinerator - Site 34 ........................................................... 1-31.3.5 Bluff Dumping Ground - Site 46 ................................................. 1-31.3.6 Powder Incinerator - Site 56 ........................................................ 1-41.3.7 Ravine Dumping Ground - Site 59 .............................................. 1-41.3.8 Burning Ground Landfill - Site 60............................................... 1-4Section 2 Corrective Measure Objectives..................................................................................... 2-12.1 RCRA Corrective Action Goals............................................................... 2-12.2 Development of Media Cleanup Standards ............................................. 2-22.2.1 Current and Future Land Use....................................................... 2-22.2.2 Human Health Risk-Based Cleanup Levels................................. 2-32.2.2.1 Media and Chemicals of Potential Concern.................. 2-32.2.2.2 Potential Exposure Pathways ........................................ 2-32.2.2.3 Calculation of Media Cleanup Level for Lead ............. 2-42.2.2.4 Summary of Media Cleanup Level CalculationResults........................................................................... 2-72.2.3 Ecological Risk-Based Cleanup Levels ....................................... 2-72.2.3.1 Approach....................................................................... 2-72.2.3.2 Media and Chemicals of Potential Concern.................. 2-82.2.3.3 Preliminary Risk-Based Media Concentrations............ 2-82.2.3.4 Residual Ecological Exposures..................................... 2-92.2.3.5 Summary of Results...................................................... 2-92.2.4 Proposed Media Cleanup Standards ............................................ 2-92.3 State of Indiana Waste Management Requirements ................................ 2-92.4 Proposed Corrective Measure Objectives.............................................. 2-10Section 3 Alternative Development ............................................................................................... 3-13.1 Corrective Measure Approach ................................................................. 3-13.1.1 Range of Potential Corrective Measures...................................... 3-13.1.2 Site Characteristics that Affect Design and Construction ofa Corrective Measure ................................................................... 3-13.1.2.1 Protection of Endangered Species ................................ 3-13.1.2.2 Areas and Volumes of Affected Media ........................ 3-23.1.2.3 Contaminant Characteristics ......................................... 3-33.2 Identification and Screening of Potential Technologies .......................... 3-33.2.1 Initial Screening of Technologies and Process Options .............. 3-33.2.2 Final Screening of Technologies and Process Options................ 3-4TABLE OF CONTENTSQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA ii3.2.2.1 Screening Criteria for Process Options......................... 3-43.2.2.2 Summary of Screening Results..................................... 3-53.3 Identification of Corrective Measure Alternatives .................................. 3-53.3.1 CMA-1, No Action ...................................................................... 3-53.3.2 CMA-2, Institutional Controls and Monitoring ........................... 3-53.3.2.1 Description of CMA-2 .................................................. 3-53.3.2.2 Effectiveness-of CMA-2............................................... 3-63.3.2.3 Implementability-of CMA-2......................................... 3-63.3.3 CMA-3, Removal and Disposal................................................... 3-63.3.3.1 Description of CMA-3 .................................................. 3-63.3.3.2 Effectiveness-of CMA-3............................................... 3-73.3.3.3 Implementability-of CMA-3......................................... 3-83.3.4 CMA-4, Composite Cap with Institutional Controls andMonitoring ................................................................................... 3-83.3.4.1 Description of CMA-4 .................................................. 3-83.3.4.2 Effectiveness-of CMA-4............................................... 3-93.3.4.3 Implementability-of CMA-4......................................... 3-93.3.5 CMA-5, Soil Cover with Institutional Controls andMonitoring ................................................................................. 3-103.3.5.1 Description of CMA-5 ................................................ 3-103.3.5.2 Effectiveness-of CMA-5............................................. 3-103.3.5.3 Implementability-of CMA-5....................................... 3-103.3.6 CMA-6, Consolidation and Composite Cap withInstitutional Controls and Monitoring ....................................... 3-113.3.6.1 Description of CMA-6 ................................................ 3-113.3.6.2 Effectiveness-of CMA-6............................................. 3-113.3.6.3 Implementability-of CMA-6....................................... 3-123.3.7 CMA-7, Consolidation and Soil Cover with InstitutionalControls and Monitoring............................................................ 3-123.3.7.1 Description of CMA-7 ................................................ 3-123.3.7.2 Effectiveness-of CMA-7............................................. 3-133.3.7.3 Implementability-of CMA-7....................................... 3-133.3.8 CMA-8, Partial Removal/Disposal and Composite Capwith Institutional Controls and Monitoring ............................... 3-133.3.8.1 Description of CMA-8 ................................................ 3-133.3.8.2 Effectiveness-of CMA-8............................................. 3-143.3.8.3 Implementability-of CMA-8....................................... 3-143.3.9 CMA-9, Partial Removal/Disposal and Soil Cover withInstitutional Controls and Monitoring ....................................... 3-153.3.9.1 Description of CMA-9 ................................................ 3-153.3.9.2 Effectiveness of CMA-9 ............................................. 3-163.3.9.3 Implementability-of CMA-9....................................... 3-16Section 4 Feasibility Level Cost Estimates................................................................................... 4-14.1 Sensitivity Analysis ................................................................................. 4-2TABLE OF CONTENTSQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA iiiSection 5 Detailed Screening of Alternatives............................................................................... 5-15.1 Detailed Screening Criteria...................................................................... 5-15.1.1 Threshold Criteria ........................................................................ 5-15.1.2 Balancing Criteria ........................................................................ 5-15.2 Detailed Screening Evaluation................................................................. 5-25.3 Comparison of Alternatives ..................................................................... 5-25.3.1 Threshold Criteria ........................................................................ 5-25.3.2 Balancing Criteria ........................................................................ 5-2Section 6 Proposed Corrective Measure Alternative................................................................... 6-16.1 Summary of Proposed Corrective Measure Alternative .......................... 6-16.2 Data Gaps and Uncertainties.................................................................... 6-2Section 7 References..................................................................................................................... 7-1TABLE OF CONTENTSQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA ivList of TablesTable 2-1 Parameter Values Used With EPA Adult Lead Exposure Model Methodologyto Derive Action Levels For LeadTable 2-2 Chemicals of Potential Ecological Concern and Preliminary Risk BasedConcentrationsTable 3-1 Initial Screening of Remedial Technologies and Process OptionsTable 3-2 Final Screening of Remedial Technologies and Process OptionsTable 4-1 Cost Estimate Summary – Alternative 2: Institutional Controls andMonitoring (ICM)Table 4-2 Cost Estimate Summary – Alternative 3: Removal and LandfillTable 4-3 Cost Estimate Summary – Alternative 4: Composite Cap with ICMTable 4-4 Cost Estimate Summary – Alternative 5: Soil Cover with ICMTable 4-5 Cost Estimate Summary – Alternative 6: Consolidate and Cap with ICMTable 4-6 Cost Estimate Summary – Alternative 7: Consolidate and Cover with ICMTable 4-7 Cost Estimate Summary – Alternative 8: Landfill and Cap with ICMTable 4-8 Cost Estimate Summary – Alternative 9: Landfill and Cover with ICMTable 4-9 Cost Estimate Sub-Element – MonitoringTable 4-10 Cost Estimate Sub-Element – Remove and DisposeTable 4-11 Cost Estimate Sub-Element – Composite CapTable 4-12 Cost Estimate Sub-Element – Vegetated Soil CoverTable 4-13 Cost Estimate Sub-Element –ConsolidationTable 4-14 Comparison of Total Cost of Remedial AlternativesTable 4-15 Results of Sensitivity Analysis for Remedial AlternativesTable 5-1 Evaluation of Corrective Measure AlternativesList of FiguresFigure 1-1 Site Location MapFigure 2-1 Decision Diagram for Development of Corrective Measure ObjectivesFigure 3-1 Site Plan for Alternative 3Figure 3-2 Site Plan for Alternatives 4 and 5Figure 3-3 Composite Cap and Soil Cover SectionsFigure 3-4 Site Plan for Alternatives 6, 7, 8, and 9List of AppendixesAppendix A Ecological Risk CharacterizationAppendix B Ecological Risk CalculationsList of AttachmentsAttachment 1 Technical MemorandaExecutive Summary Burning Ground AreaQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA ES-1The following includes the Corrective Measures Study (CMS) based on data collected during thePhase I Remedial Investigation (RI) (Woodward-Clyde, 1998) and Phase II ResourceConservation and Recovery Act (RCRA) Facility Investigation (RFI) (URS, 2001) completed atthe Burning Ground Area (Sites 26, 27, 28, 34, 46, 54, 59, and 60) at the Indiana ArmyAmmunition Plant (INAAP).INAAP Background. INAAP currently encompasses approximately 9,790 acres in south-centralClark County, Indiana. Its southern boundary is approximately 6 miles north ofJeffersonville, Indiana and 10 miles from the Louisville, Kentucky metropolitan area, which liesto the south across the Ohio River. INAAP is an inactive military industrial installation. TheArmy intends to transfer the property to the Local Reuse Authority for commercial developmentor to the State of Indiana for inclusion in the state park system. The Burning Ground Areaincludes eight of 90 sites identified at INAAP.The Plant was originally constructed as three separate facilities: The Indiana Ordnance WorksPlant 1, the Hoosier Ordnance Plant, and the Indiana Works Plant 2. The three facilities wereconsolidated into the Indiana Arsenal in 1945. The Indiana Arsenal was redesignated as theIndiana Ordnance Plant in 1961; in August 1963, it was redesignated again as the Indiana ArmyAmmunition Plant.Topography at the INAAP can be described as a middle-aged karst topography. Karsttopography is produced by the dissolution of limestone, gypsum, or other readily soluble rocks,commonly along joints, fractures, bedding planes, or other such features. The dissolutionprocess results in the formation of sinkholes, caves, and underground drainage. Numeroussinkholes and springs are found throughout much of INAAP.Approximately 96 percent of INAAP’s land surface drains directly into the Ohio River via sevendrainage basins. The remaining 4 percent reaches the Ohio River indirectly through the PheasantRun basin.Groundwater at INAAP is present in the bedrock formations of the upland areas and in theterrace/floodplain sand and gravel deposits located within the Ohio River valley. Thegroundwater present in the floodplain aquifer along the Ohio River is a major water supplysource. Groundwater is not usually found in the thin soil layer covering the bedrock surface inthe upland areas. When present, shallow groundwater typically mingles with surface water byflowing in and out of karst features.Burning Ground Area Background. The Burning Ground Area was formerly used as a wasteincineration and/or disposal area for INAAP. The Burning Ground Area comprises eight sitesthat are nearly contiguous. The entire Burning Ground Area (i.e., the eight sites and the areasbetween sites) covers about 56 acres. The eight sites are:· The Old Trash Burning Area (Site 26) covers about 1.2 acres· The Lead Storage Building 714-5 (Site 27) covers about 0.1 acre· The Drainage Area Dumping Ground (Site 28) covers about 0.7 acres· The Trash Incinerator (Site 34) covers about 0.1 acreExecutive Summary Burning Ground AreaQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA ES-2· The Bluff Dumping Ground (Site 46) covers about 5 acres· The Powder Incinerator (Site 56) covers about 0.1 acre· The Ravine Dumping Ground (Site 59) covers about 3.5 acres· The Burning Ground Landfill (Site 60) covers about 5.2 acresThe Burning Ground Area sites are expected to be defined as “open dumps” under 329 IAC 10-2-128, and are therefore expected to be regulated under Indiana Administrative Code 329, SolidWaste Land Disposal Facilities (329 IAC 10-4-1 through 329 10-4-4, Open Dumping andDumps). The Indiana Administrative Code generally requires removal of debris from opendumps and disposal at a licensed solid waste facility. However, the Indiana Administrative Codeallows for the Commissioner to approve alternative cleanup methods besides removal anddisposal, such as leaving the debris on site with an approved cover.Scope of CMS. The scope of the CMS includes:· Identifying remedial alternatives that are tailored to meet the corrective measure objectivesoutlined in the Phase II RFI (URS, 2001) and further defined in this report· Developing remedial technologies and process options considered to be suitable for the siteand contaminant characteristics· Screening the corrective measure alternatives using the following criteria:– “Threshold criteria”: Protective of human health and the environment; attain mediacleanup standards; control source(s) of release; and comply with applicable wastemanagement standards– “Balancing criteria”: Long-term reliability and effectiveness; reduction of toxicity,mobility, or volume (TMV) of waste; short-term effectiveness; implementability; andcost· Recommending a proposed corrective measureHuman Health and Ecological Risk Assessments. The baseline risk assessments completedduring the Phase II RFI has determined that the combined Burning Ground Area sites do notpose imminent threats to human health and the environment. Therefore, interim action tostabilize the sites is not necessary or appropriate.An assessment of potential exposures to lead has determined that a cleanup level for lead equalto 1,700 mg/kg is protective of hypothetical construction workers as well as child recreators.Potential exposures to chemicals of potential ecological concern (COPECs) along severalpathways were found to exceed established benchmarks. Based on an ecological risk analysis ofall COPECs, no additional exposure reduction would be required for protection of the ecosystemif the debris areas are covered and soil containing lead at levels above 1,700 mg/kg are coveredor removed.Corrective Measure Objectives. The proposed corrective measure objectives for the BurningGround Area sites are focused on complying with Indiana solid waste regulations and reducingExecutive Summary Burning Ground AreaQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA ES-3the potential risk to human health with concurrent protection of ecological receptors and theenvironment. The proposed corrective measure objectives are:· Remove or cover landfill debris to comply with State of Indiana solid waste rules.· Reduce potential human exposures to all Chemicals of Potential Concern (COPCs) in theupper two feet of soil/sediment within the Burning Ground Area. Based on reasonable futureland use and human health risk assessment techniques, unacceptable human health risks canbe eliminated by controlling exposure to lead to the following media cleanup level:– Lead = 1,700 mg/kg– The ecological risk assessment found that elimination of exposure to the mediacleanup levels listed above would provide significant reduction of exposure potentialswithin the Burning Ground Area.· Control potential migration of all COPECs to off-site receptors that may result from thetransport of contaminated soil and sediment in storm water runoff.Alternatives Considered. The following nine Corrective Measures Alternatives (CMA) wereevaluated in the draft CMS:· CMA-1: No Action· CMA-2: Institutional Controls and Monitoring (ICM)· CMA-3: Removal and Landfill· CMA-4: Composite Cap with ICM· CMA-5: Soil Cover with ICM· CMA-6: Consolidate and Cap with ICM· CMA-7: Consolidate and Cover with ICM· CMA-8: Landfill and Cap with ICM· CMA-9: Landfill and Cover with ICMBased on Army requests, an additional four alternatives were evaluated as follows:· CMA-10: Removal and On-Site Landfill· CMA-11: Removal and Disposal at Old Landfill (Site 1) with a Vegetated Soil Cover· CMA-12: Removal and Disposal at Old Landfill (Site 1) with Composite Liner and Cap· CMA-13: Soil Stabilization, Excavation, and Disposal (Sites 27, 28, 34, and 56)Recommended Corrective Measure Alternative. CMA-5 was originally recommended as thepreferred alternative in the draft CMS. However, since the draft CMS was issued, the possibilityof removing the contaminated media and landfill debris from several of the Burning GroundArea sites to obtain closure has been further assessed. Based on the results of the draft CMS andon the subsequent preference for obtaining closure, CMA-13 is recommended as the preferredExecutive Summary Burning Ground AreaQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA ES-4alternative; it offers the added benefit of the added benefit of closing four of the Burning GroundArea sites (Sites 27, 28, 34, and 56). The components of CMA-13, which adds a soilstabilization and off-site disposal component to CMA-5, are outlined below:· Institutional controls (only Sites 26, 46, 59, and 60) – Land use restrictions to prevent sitedevelopment with periodic administrative checks to ensure that no development occurs in thefuture.· Soil stabilization and off-site disposal of lead-contaminated soil (only Sites 27, 28, 34, and56) – Stabilize soils from these sites that have lead concentrations greater than 1,300 mg/kg(the IDEM direct soil exposure screening value for industrial sites) by tilling in commerciallyavailable stabilizing reagent, transport and dispose of treated material off site as Subtitle Dwaste, collect and analyze confirmatory samples from the base of the excavations, andfill/grade excavations as necessary to blend finish grades into the surrounding grades.· Containment of all areas with contaminated media (all Burning Ground Area sites) – Clearvegetation, grade the sites to develop positive drainage, and install a 2-foot-thick vegetatedsoil cover.· Long-term monitoring (only sites 26, 46, 59, and 60) – Quarterly sample surface water andsediment during the first five years of the corrective action, annually sample surface waterand sediment during the remainder of the corrective action, and semi-annually inspect sitesand repair soil cover (as necessary) to maintain its effectiveness.CMA-13 has an estimated present worth cost of about $2.3 million. CMA-13 is recommendedbecause it is protective of human health and the environment, it is more cost-effective than otheralternatives designed to provide a similar degree of protection, and it offers the benefit of closingfour of the Burning Ground Area sites (Sites 27, 28, 34, and 56), which should eliminate theneed for long-term monitoring at these sites. In addition, CMA-13 uses proven and reliabletechnology that is easily and readily implementable.CMA-13 will require approval from the IDEM Land Quality Office.SECTIONONE BackgroundQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 1-1This report is the Corrective Measures Study (CMS) for the Burning Ground Area (Sites 26, 27,28, 34, 46, 56, 59, 60) located at the Indiana Army Ammunition Plant (INAAP).1.1 PURPOSE AND SCOPE OF CORRECTIVE MEASURES STUDYA Phase I Remedial Investigation (RI) (Woodward-Clyde, 1996) and a Phase II ResourceConservation and Recovery Act (RCRA) Facility Investigation (RFI) (URS, 2001) have beencompleted to characterize the physical and chemical conditions at the Burning Ground Area.The purpose of this CMS is to identify and evaluate potential remedial alternatives for theBurning Ground Area. The eight sites in the Burning Ground Area were combined because theyare nearly contiguous and contaminants of concern are similar.This CMS is based on data collected during the Phase I RI and Phase II RFI at the BurningGround Area. The scope of the CMS includes:· Identifying remedial alternatives that are tailored to meet the corrective measure objectivesoutlined in the Phase II RFI (URS, 2001) and further defined in this report· Developing remedial technologies and process options considered to be suitable for the siteand contaminant characteristics· Screening the corrective measure alternatives using the following criteria:– “Threshold criteria”: Protective of human health and the environment; attain mediacleanup standards; control source(s) of release; and comply with applicable wastemanagement standards– “Balancing criteria”: Long-term reliability and effectiveness; reduction of toxicity,mobility, or volume (TMV) of waste; short-term effectiveness; implementability; andcost· Recommending a proposed corrective measure1.2 ENVIRONMENTAL STATUSEnvironmental investigations and remediation at INAAP are being completed under the DoD’sDefense Environmental Restoration Program (DERP). The legal foundation for the DERP is theComprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA)and the Superfund Amendments and Reauthorization Act of 1986 (SARA). Specifically,CERCLA Section 120 applies to Federal Facilities, and SARA Section 211 establishes theDERP. The objectives of DERP are to identify and investigate sites with past hazardous wastedisposal or releases and to address them.INAAP formerly had a RCRA permit for open burning of obsolete or spent explosives, and willbe receiving a RCRA post-closure care permit for long-term monitoring of a landfill.Consequently, the Indiana Department of Environmental Management (IDEM) is the leadagency providing oversight for all corrective measure activities at INAAP in accordance with theRCRA corrective action program. IDEM has developed the Risk Integrated System of ClosureSECTIONONE BackgroundQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 1-2(RISC) Technical Resource Guidance Document(www.in.gov/idem/land/risc/tech_guide/risc_guidance.pdf, February 15, 2001) to serve as aflexible framework for closure of sites under the RCRA corrective action program. The RISCguidance, RCRA corrective action program, and CERCLA remedial program are generallyconsistent with each other and should result in similar environmental solutions.1.3 SITE HISTORYThe Indiana Army Ammunition Plant (INAAP) currently encompasses approximately 9,790acres in south central Clark County, Indiana. Its southern boundary is approximately 6 milesnorth of Jeffersonville, Indiana and 10 miles from the Louisville, Kentucky metropolitan areathat lies to the south across the Ohio River. INAAP was a Government-Owned, Contractor-Operated (GOCO) military industrial installation that operated from 1941 to 1998. INAAP isinactive, and the Army intends to transfer the property to a Local Reuse Authority (LRA) forcommercial development or to the State of Indiana for inclusion in the state park system.The Burning Ground Area was formerly used as a waste incineration and/or disposal area forINAAP. The Burning Ground Area comprises eight sites that are nearly contiguous (see Figure1-1). The entire Burning Ground Area (i.e., the eight sites and the areas between sites) coversabout 56 acres. Detailed site histories and discussion of previous site investigations arepresented in the Phase II RFI report (URS, 2001). The operational histories and wastecharacteristics for the Burning Ground Area sites, based on interviews, aerial photographs,records review, and site reconnaissance, are summarized below.1.3.1 Old Trash Burning Area - Site 26The Old Trash Burning Area (Site 26) covers about 1.2 acres. The site is relatively flat with rockand rubble located at the surface. The site is located at the southern end of the Burning GroundArea along the drainage that leads to the Jenny Lind Pond. Site 26 was formerly used to burngarbage and general refuse prior to 1969 (ASI 1994). No historical records regarding the volumeof waste materials burned at this site exist.Eight soil borings and ten trenches were completed at the site during the Phase I RI and Phase IIRFI. Soil borings and trenches indicate that ash and debris are present over an area of about 1.2acres, at depths up to 15 feet below ground surface (bgs). Chemical analysis of soil samplesfrom the site found elevated levels of eight SVOCs, three nitroaromatics, and six metals.1.3.2 Lead Storage Building 714-5 - Site 27The Lead Storage Building 714-5 (Site 27) was constructed in 1941 (ICI 1991) and covers about0.1 acres. The site is located on the side of a hill and slopes toward the south. Runoff from thesite drains toward Sites 34 and 59 and then into two drainages that lead to Jenny Lind Pond.Activity at the site included melting scrap lead construction materials from the nitric acid plantand nitrating lines, and casting it into ingots. The amounts of lead processed and exact dates ofoperation are unknown.SECTIONONE BackgroundQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 1-3Seven soil borings were completed at the site during the Phase I RI and Phase II RFI. Soilborings and trenches indicate that fill and debris are present over an area of about 2,200 squarefeet, at depths up to four feet bgs. Chemical analysis of soil samples from the site found elevatedlevels of two metals.1.3.3 Drainage Area Dumping Ground - Site 28The Drainage Area Dumping Ground (Site 28) covers about 0.7 acres. The site is located at thesouthern end of the Burning Ground Area on a hill slope along the drainage that leads to theJenny Lind Pond. The site was reportedly used as a disposal area for waste material. A fewempty drums and some scrap metal were observed in the drainage during the site reconnaissance.No historical records regarding the volume of waste materials disposed at this site exist.Two soil borings and three trenches were completed at the site during the Phase I RI and Phase IIRFI. Soil borings and trenches indicate that fill and debris are present over an area of about3,500 square feet, at depths up to 4 feet bgs. Chemical analysis of soil samples from the sitefound elevated levels of three SVOCs, one nitroaromatic, and three metals.1.3.4 Trash Incinerator - Site 34The Trash Incinerator (Site 34) covers about 0.1 acres. The site is located between Sites 26 and27 along a side of a hill. The site slopes and runoff drains toward the south in to a drainage thatleads to Jenny Lind Pond. Soil at the site is shallow (zero to one foot) and bedrock outcrops overmost of the site. The site was used to burn an unknown quantity of waste paper and the disposalprocess and location of ash from the site is unknown.One trench was completed at the site during the Phase I RI and Phase II RFI. The trench did notindicate that ash or debris is present. Chemical analysis of soil samples from the site foundelevated levels of one nitroaromatic and three metals.1.3.5 Bluff Dumping Ground - Site 46The Bluff Dumping Ground (Site 46) covers about 5 acres. The site is located at the north end ofthe Burning Ground Area. The site is composed of a relatively flat area and a steep bluff thatleads to the Ohio River. The site was used for disposal of construction debris, railroad ties,empty powder cans, asphalt roofing material, iron pipe, corrugated metal siding, empty 55-gallondrums, concrete, transite siding material, tar-coated drums, brick, gravel, and miscellaneousscrap metal. No historical records regarding the volume of waste materials deposited at this siteexist.Thirty-six soil borings were completed at the site during the Phase I RI and Phase II RFI. Soilborings indicate that fill and debris are present over an area of about 3.7 acres, at depths up to 9.3feet bgs. Chemical analysis of soil samples from the site found elevated levels of nine SVOCsand one metal.SECTIONONE BackgroundQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 1-41.3.6 Powder Incinerator - Site 56The Powder Incinerator (Site 56) covers about 0.1 acres. The site is located north of Site 27along the side of a hill. The incinerator was used to burn waste nitrocellulose and wastepropellant. No historical records regarding the volume of waste materials burned, the fate of theincinerator, residues or ash, nor the startup date of the site exists.Four soil borings were completed at the site during the Phase I RI and Phase II RFI. Soil boringsindicate that fill and debris are present over an area of about 3,000 square feet, at depths up to 2.6feet bgs. Chemical analysis of soil samples from the site found elevated levels of one metal.1.3.7 Ravine Dumping Ground - Site 59The Ravine Dumping Ground (Site 59) covers about 3.5 acres. The site is located on thesouthwest corner of the Burning Ground Area. The site is located on a slope that drains into theJenny Lind Pond. The material at the site includes empty propellant drums, empty 55-gallondrums, propellant drum lids, drum lid rings, roofing materials, metal siding, gravel, and someconcrete were also observed and lids. During the 1960s, residues from the burning area weredumped at the site. No historical records regarding the volume of waste materials deposited atthis site exist.Thirty-two soil borings were completed at the site during the Phase I RI and Phase II RFI. Soilborings indicate that fill and debris are present over an area of about 1.94 acres. The boringsshowed fill at depths up to 2.5 feet bgs, but there is an area of compacted drums and lids that isaround ten feet deep. Chemical analysis of soil samples from the site found elevated levels of sixSVOCs, four nitroaromatic, and five metals.1.3.8 Burning Ground Landfill - Site 60The Burning Ground Landfill (Site 60) covers about 5.2 acres. The site is located in the middleof the burning ground area along a slope that drains through Sites 27, 34 and 26. The surface ofthe site is vegetated and undulating. The Burning Ground Landfill was an unlined landfilloperated from 1940 to 1945 and again from 1951 to 1957 (ASI 1994). No historical recordsregarding the volume of waste materials deposited at this site exist.Seventeen soil borings and fifteen trenches were completed at the site during the Phase I RI andPhase II RFI. Soil borings and trenches indicate that fill and debris are present over an area ofabout four acres, at depths up to 11.9 bgs. Chemical analysis of soil samples from the site foundelevated levels of three VOC, eight SVOC, one pesticide, one nitroaromatic, and two metals.SECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 2-1The baseline risk assessments completed during the Phase II RFI have determined that thecombined Burning Ground Area sites do not pose imminent threats to human health and theenvironment. Therefore, interim action to stabilize the sites is not necessary or appropriate.Using highly conservative assumptions, the following preliminary corrective measure objectiveswere identified during the Phase II RFI to address environmental contamination at the sites:· Potential exposures to chemicals of concern along several ecological pathways exceedestablished benchmarks. The primary pathways are potential exposures to chemicals ofconcern in the soil matrix and in organisms associated with a terrestrial-based food chain.An objective of the corrective measure study should be to reduce ecological exposures toacceptable levels through “hot spot” removal and/or capping (covering).· Calculated carcinogenic and non-carcinogenic risks to human health are within IDEM andEPA acceptable levels. However, these calculations potentially underestimate risk becausethey do not include exposure to lead which has levels exceeding the EPA action level of 400ppm. Therefore, an objective of the corrective measure study should be to reduce humanexposure to acceptable levels through “hot spot” removal and/or capping (covering).Additionally, the corrective measure study should evaluate the bioavailability and/orleachability of lead based on TCLP data.· Potential corrective measure alternatives at the Burning Ground Area should be evaluated inconjunction with other sites along the Jenny Lind Run drainage basin, in particular runofffrom the area that discharges into the drainages that lead to Jenny Lind Pond. An objectiveof the corrective measures study should be to control downgradient migration ofcontaminants through removal, treatment, and/or capping.These preliminary corrective measure objectives are further delineated in this section to developproposed final corrective measure objectives for the Burning Ground Area.2.1 RCRA CORRECTIVE ACTION GOALSFinal remedies implemented under RCRA are expected to achieve the following “thresholdcriteria”:· Protect human health and the environment· Attain media cleanup standards as appropriate for the current and reasonably anticipatedfuture land use, as well as Indiana Code requirements· Address the source(s) of releases to reduce or eliminate, to the extent practicable, furtherreleases of hazardous constituents that may pose a significant threat to human health or theenvironment· Comply with applicable standards for waste management during the corrective measureThe EPA has developed these “threshold criteria” as an initial screening tool for potentialremedies. Remedies that meet the “threshold criteria” are further screened using “balancingcriteria” to identify a final remedy that provides an appropriate combination of attributes.SECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 2-22.2 DEVELOPMENT OF MEDIA CLEANUP STANDARDSOf the four “threshold criteria” listed above, attainment of media cleanup standards requires thedevelopment of standards that are site-specific and media-specific. The term media cleanupstandards typically refers to broad cleanup objectives and often includes:· Media cleanup levels: Media-specific concentrations of hazardous constituents developedusing available regulatory risk-based standards (e.g., maximum contaminant levels or statestandards for drinking water) or site-specific risk assessment.· Point(s) of compliance: Location(s) at which the media cleanup levels are achieved.· Compliance time frame: Time period and schedule according to which the correctivemeasure will be implemented.Site-specific human health and ecological risk assessments have been completed for BurningGround Area. These risk assessments considered all chemicals of potential concern detected inenvironmental media during the Phase I RI and Phase II RFI. The results of the risk assessmentsare further developed to identify appropriate media cleanup standards for the two sites, based oncurrent and future land use, media and chemicals of concern, and potential exposure pathways.2.2.1 Current and Future Land UseThe Burning Ground Area is located in an upland area on a bluff overlooking the Ohio Riverwhich is located to the east. Several ravines that drain the Burning Ground Area empty intoJenny Lind Pond. In general, the ravines carry water only during precipitation events; however,small portions of several ravines appear to be connected to groundwater and flow most of thetime.The Jenny Lind Run drainage basin supports a threatened and endangered species, the gray bat,particularly upstream of the Jenny Lind Pond where caves serve as nesting areas for the gray bat.The Burning Ground Area sites drain into Jenny Lind Pond downstream of the cave resources,therefore the ravines are not likely used by the gray bat for foraging. Even so, there are potentialimpacts on the gray bat and these are a consideration for any corrective measure at the BurningGround Area sites. Consultation with the U.S. Fish and Wildlife Service (USFWS) is requiredunder Section 7 of the Endangered Species Act for any corrective measure that will impact thegray bat or its habitat.The various sites that make up the Burning Ground Area were formerly used for incinerationand/or disposal of waste. The current site conditions range from steep embankments with visibledebris to hummocky upland areas where previous landfilling activities took place. Bedrock isexposed in some of the embankments and drainages, and occasionally in the upland area.Currently, the sites are not used and are overgrown with grass, shrubs, and small trees.Institutional controls have already been implemented throughout the INAAP facility, includingthe Burning Ground Area, in the form of State legislation that restricts the future land use toagricultural, commercial, industrial, or State park. The expected future land use is as a Statepark.SECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 2-32.2.2 Human Health Risk-Based Cleanup LevelsMedia cleanup levels specific to human health risk reduction are developed in this subsection.Cleanup levels were developed for all the chemicals of potential concern (COPCs) that wereidentified in the risk assessment as significantly contributing to a receptor pathway risk if thecalculated risk either:· Exceeds a 1 x 10-5 cancer risk (the target cancer risk level recommended by the State ofIndiana)· Exceeds a noncarcinogenic hazard index (HI) of 12.2.2.1 Media and Chemicals of Potential ConcernAll COPCs and all contaminated media found at the Burning Ground Area sites were consideredduring the human health baseline risk assessment. The results of the human health baseline riskassessment indicated that soil and sediment are the only media that pose a potential human healthrisk.Averaging the combined chemical data for both surface soil and sediment at the Burning GroundArea did not result in significant risk for any of the receptors. However, the distribution ofcontaminants suggests that if all exposure occurred in certain areas (Site 26, Site 27, Site 28, andSite 34) a potential human health risk may exist. The highest concentrations of lead wereobserved at Site 26; therefore, the exposure point concentrations for lead at Site 26 were used inthe baseline risk assessment to estimate human health risk. Using only this site is highlyconservative because it assumes that all exposure would take place in these 1.2 acres.Lead is a naturally occurring element. Chronic exposure to small quantities of lead can causepermanent developmental problems in children and at higher concentrations, lead causesneurological problems and interferes with red blood cell formation. Adverse health effects (ie.,changes in enzyme levels, neurobehavioral development) may occur at blood lead levels so lowthat they can not be measured, and EPA withdrew its reference dose ( RfD) for lead in 1989.2.2.2.2 Potential Exposure PathwaysCleanup levels were calculated for the most sensitive hypothetical future receptors: aconstruction worker and a child recreator. The following assumptions were made:· A construction worker would be exposed to site contaminants 40 days per year on average,and over a 56 day period in a single year for short term activities· A child recreator would be exposed during site visits 48 days per yearSECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 2-42.2.2.3 Calculation of Media Cleanup Level for LeadConstruction WorkerBecause there is uncertainty regarding the blood lead level of concern in adults, cleanup levelsfor the construction worker scenario have been derived for three blood lead levels of concern: 25(DHHS, 1997), 30 (FDA, 1990; Carrington and Bolger, 1992; Carrington et al. 1993; ACGIH,1994; 1999; OSHA, 1991) and 40 mg/dl (OSHA, 1978; WHO, 1980). The actual extent and rateof oral absorption of lead in humans is influenced by physiological states of the exposedindividuals (e.g., age, fasting, nutritional status), physiochemical characteristics of the mediumand type of lead ingested (e.g., type of medium, particle size, mineralogy, lead solubility andspecies), and lead dose (ATSDR, 1999). A number of factors may reduce oral bioavailability oflead in soil relative to that for soluble forms of lead (Chaney, 1989), including:· The presence of lead in discrete mineral phases in soil· Encapsulation of lead inside of insoluble particles in soil· Larger particle sizes of lead in soilSite-specific bioavailability values lower than those assumed in USEPA lead models have beenreported for lead in mining waste and weathered siliceous industrial slag (Freeman et al., 1992,1994, 1996, Dieter et al., 1993; Davis et al., 1997). For example, gastrointestinal absorptionfractions as low as 1% have been reported in animals fed less-soluble lead forms from miningwaste in soil. Analysis of lead mineralogy at some sites showed that lead was present inrelatively insoluble, discrete mineral phases (e.g., lead phosphate) and was encapsulated inside ofparticles (e.g., in silicates) (Davis et al., 1993; Davis et al., 1997). A study by Baltrop and Meek(1979) found a 2.3-fold decrease in lead bioavailability in rats ingesting metallic lead with aparticle size of 150 to 200 μm compared to a particle size of 38 μm.Much of the lead detected in soil at the Burning Ground Area sites consists of large particles ofinsoluble, metallic lead. Therefore, the bioavailability of lead from the site, ingested by adulthumans, is probably low and may even approach zero. A reasonable, yet conservative, estimateof bioavailability of insoluble, metallic lead ingested by construction workers at the site is 5%,instead of the EPA default value of 12% for soluble lead in soil. Assuming a 5% bioavailabilityand a 95th percentile adult blood lead concentration (PbBadult, 0.95 goal) of 25 mg/dl, the resultingmedia cleanup level for lead in soil/sediments for the hypothetical construction worker exposurepathway is 4,828 mg/kg (calculations shown below).fetal/maternal,adultfetal, 0.95 goaladult, central, goal*Ri1.645GSDPbBPbB =3.87 g/dL1.910 / / 0.9PbB adult, central, goal 1.645 mm= =g dLSECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 2-5Cleanup Level(BKSF*IR*AF*EF)(PbB - PbB ) *AT adult, central, goal adult,0 =[ ] 1450 g/g Cleanup Level0.4 / / *0.100 / *0.05*40 /(3.87 / 1.8 / )*(56 / )= =-mm mm mg dL per g day g soil day days yearg dL g dL days yearUsing the equations above, alternate cleanup levels for the hypothetical construction workerexposure pathway are 6046 and 8481 mg/kg for PbBadult, 0.95 goal values of 30 and 40 mg/dl,respectively. A detailed description of parameter values used in the above equations can befound in Table 2-1. The EPCs for lead at the site of 1,024 mg/kg for total soil/sediments and1,229 mg/kg for surface soil/sediments are below this action level, indicating that lead insoil/sediments at the site may not pose a health threat to construction workers at the presumedlead bioavailability value of 5%.Child RecreatorEPA has developed a soil screening level of 400 mg/kg lead for residential exposure (EPA1994a). The residential standard was derived using EPA’s Integrated ExposureUptake/Biokinetic (IEUBK) model (EPA 1994b). The model predicts that young childrenexposed to lead in soil/dust at concentrations of 400 mg/kg and to background concentrations oflead in air, drinking water, and the diet for 365 days/year would have an estimated risk of nogreater than 5 percent of exceeding a 10 μg/dL blood lead level of concern (EPA 1994b). This isthe target blood lead distribution identified in EPA guidance as posing an acceptable level of riskin children (EPA 1994a).There are no plans for residential use of the Burning Ground Area sites. Therefore, risk and risk-basedactions have been evaluated based on a recreational scenario where children visit the siteoccasionally (48 days per year). In this section, the potential threat to human health fromexposure of child recreational visitors to lead in soil/sediments at the site is evaluated bycalculating an average daily EPC of lead in soil/sediments at the site and soil/dust at theresidence.Child recreational visitors to the site are assumed to be exposed to a site-specific EPC insoil/sediment during their visits to the site and to a background EPC in soil/dust on days whenthey do not visit the site. Blood lead levels in the child visitor are expected to correspond toaverage long-term daily exposure to lead in soil/dust, because steady-state blood lead levels inchildren reflect overall long-term exposure to lead, rather than day-to-day changes in exposure(Van Leeuwen, personal communication).The following equation was used to calculate a time-weighted average daily exposure pointconcentration for lead in soil/sediments for child visitors exposed both at the site and tobackground levels of lead in soil/dust offsite.Ca = ([EPC s * EFs] + [Co * EFo])/ EFtwhereSECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 2-6Ca = Time-weighted average exposure point concentration of lead (mg/kg)EPCs = Exposure point concentration of lead in soil/sediments onsite (mg/kg)= 1,024 mg/kg for total soil/sediments; or= 1,229 mg/kg for surface soil/sedimentsEFs = Exposure frequency at the site (days/year)= 48 days per yearCo = Exposure point concentration of lead in soil/dust offsite (mg/kg)= 200 mg/kg lead in soil/dust , per EPA’s IEUBK model , Version 0.99d (EPA1994a), which is based on the high-end of a plausible background range of 75 to200 mg/kg for lead in soil and dust in urban areas (EPA 1994c)EFo = Exposure frequency offsite (days/year)= 317 days each yearEFt = Total exposure frequency (days/year)EPA guidance recommends using arithmetic average concentrations because validation studieshave show that the IEUBK models predicts blood lead levels more accurately when arithmeticaverage soil concentrations are used rather than the 95% UCL of the mean concentration (EPA1994c).Based on exposure to the EPC of 1,024 mg/kg lead (total soil/sediments), the average time-weightedexposure point concentration (Ca) is 308 mg/kg. Based on exposure to the EPC of1,229 mg/kg lead (surface soil/sediments), the average time-weighted exposure pointconcentration (Ca) is 335 mg/kg. Both of these time-weighted values are below the EPA’s soilscreening level of 400 mg/kg for residential exposure, indicating that exposure of children tolead in total soil/sediments at the site and background levels of lead in soil/dust, air, water, andthe diet at home does not pose an unacceptable health threat for the child recreator.In Section 7.3.1.6 of the Phase II RFI report, a preliminary risk-based action levels of 400 mg/kgwas identified for lead in soil/sediments based on a residential scenario assuming exposure ofchildren to soil/sediments at the site for 365 days/year. In this section, a risk-based action levelfor lead in soil/sediments at the site protective for child recreational visitors was derived bysetting the target time-weighted average exposure point concentration (Ca) equal to the soilscreening level of 400 mg/kg, and using the following equation:Cs = [(Ca * EFt) - (Co * EFo)]/ EFswhereCs = Site-specific cleanup level for lead in soil/sediments at the site (mg/kg)Ca = Target time-weighted average exposure point concentration of lead = 400 mg/kgSECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 2-7EFt = Total exposure frequency = 365 days/yearCo = Concentration of lead in soil/dust offsite = 200 mg /kg (EPA 1994c)EFo = Exposure frequency offsite = 317 days/yearEFs = Exposure frequency at the site = 48 days/yearUsing the above equation and values results in a site-specific cleanup level for lead insoil/sediment of 1,721 mg/kg, which is above the EPCs of 1,024 mg/kg for total soil/sedimentand 1,229 mg/kg for surface soil. This indicates that lead in soil/sediment at the site does notpose an unacceptable health threat for the child recreator.2.2.2.4 Summary of Media Cleanup Level Calculation ResultsThe calculated cleanup levels for the construction worker and child recreator scenarios aresummarized below. The cleanup level for lead was based on the most sensitive theoreticalreceptor at the site, the child recreator. The cleanup levels for lead were developed by thecalculating a site-specific action level for lead based on the IEUBK model and adjusting forexposure frequency or using the Adult Lead Exposure Model and adjusting for bioavailability.Calculated Human Health Risk-Based Cleanup LevelsChemical Child Recreator, HI = 1 Construction Worker, HI = 1Lead 1,721 mg/kg 4,828 mg/kgEstablishing human health risk based cleanup levels for lead equal to 1,700 mg/kg will result inaverage lead concentrations below these values across the Burning Ground Area. This isconsidered to be a conservative evaluation of potential human exposures based on current andfuture activities at the site.2.2.3 Ecological Risk-Based Cleanup LevelsMedia cleanup levels specific to ecological risk reductions are presented in the followingsubsections. The media cleanup levels reflect conservative estimates using available site-specificdata, particularly regarding the occurrence, density, and behavior of potential receptors. Becausethese data are somewhat limited, intentionally conservative assumptions have been applied. Theecological risk analysis is based on maximizing the reduction of potential exposure to protectreceptors while minimizing the extent of any corrective action to conserve resources.2.2.3.1 ApproachThe sites in the Burning Ground Area have been combined into a single “exposure unit” due tothe proximity and shared border of these sites and to the presence of nearly identical ecologicalhabitat features. The ecological receptors selected during the baseline ecological riskassessments, which include species representative of both upland and creek habitats, are believedSECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 2-8to be functional here. The intent of the cleanup levels developed in this CMS is to protect apopulation rather than an individual organism.IDEM requires certain corrective measures in the context of landfills such as those present withinthe Burning Ground Area that supercede risk-based corrective actions. The approach taken herewas to first apply those corrective actions required by IDEM Solid Waste Regulations followedby a re-evaluation of ecological exposures and risks. This approach applies the same methodsused in the risk assessments while censoring, with background or detection limit replacements,sample locations within the exposure unit remediated under the IDEM requirements. Aflowchart depicting the process is presented as Figure 2-1.Ecological risk-based concentrations are based on levels shown in the laboratory or in fieldstudies reported in the scientific literature to assure that no undue ecological harm would occurdue to the presence of chemical stressors within applicable media (i.e., soil, sediment, water, orbiological tissues). These ecological risk-based concentrations are presented in Appendix A forall ecological receptors. The censoring process employed the hazard quotient (HQ) as a metricof risk potential.In any CMS, uncertainty is relevant. Although uncertainty was unavoidable during thedevelopment of ecological corrective action objectives, most of the uncertainty is associated withthe degree to which exposures have been overestimated. A more detailed discussion of theapproach, assumptions, corrective measure scenarios evaluated, and residual risk analysis ispresented in Appendix A.2.2.3.2 Media and Chemicals of Potential ConcernThe applicable media evaluated at the site include soil, sediment, surface water, and biologicaltissues used as food. The Burning Ground Area is primarily an upland area with limited aquaticresources and is comprised of eight sites. There is a small creek associated with Site 59, whichruns about 600 feet and represents the only aquatic habitat present in the Burning Ground Area.A total of 38 chemicals were identified as chemicals of potential ecological concern (COPECs)during the ecological risk assessments for the terrestrial community within the Burning GroundArea as a whole. In the context of the limited aquatic community present within the BurningGround, 35 chemicals of potential ecological concern were identified. All of the identifiedCOPECs considered for the eight individual sites are listed according to applicable media inTable 2-2.2.2.3.3 Preliminary Risk-Based Media ConcentrationsA risk-based media concentration is a media-specific concentration below which adverse effectswould not be expected to occur. As there are multiple ecological receptors associated with theBurning Ground Area, there are multiple preliminary risk-based concentrations (PRBCs). Thelowest PRBCs for the applicable media are presented in Table 2-2. These PRBCs should not becompared to individual sample results but rather to the mean exposure level or upper limit for themean exposure level. COPEC exposure levels after implementation of the IDEM landfillrequired corrective measures do not exceed these PRBCs (see Appendix A).SECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 2-9Based on the analysis of COPECs that may have significant exposure potentials and on thedistribution of these COPECs within the sites after the regulatory driven corrective actions, noadditional exposure reduction would be required for protection of the ecosystem present, thusecologically-based cleanup levels for soil and sediment are not required.2.2.3.4 Residual Ecological ExposuresThe regulatory driven correction actions would be effective in reducing the residual exposuresassociated with all COPECs to levels considered acceptable in soil. Residual concentrations ofantimony and lead are suggested to pose a limited risk potential and remain above INAAPbackgrounds, nevertheless these residual concentrations are not believed to represent asignificant threat to the environment (see Appendix A).2.2.3.5 Summary of ResultsBased on the analysis of COPECs that may have significant exposure potentials and on thedistribution of these COPECs within the sites after the regulatory driven corrective actions, noadditional exposure reduction would be required for protection of the ecosystem present, thusecologically-based cleanup levels for soil and sediment are not required2.2.4 Proposed Media Cleanup StandardsThe following media cleanup standards are proposed:· Media of concern: Landfill debris and soil and sediment in the upper two feet of the BurningGround area.· Not-to-exceed media cleanup levels: 1,700 mg/kg lead (achieving the not-to-exceed mediacleanup levels results in acceptable mean residual exposure concentrations)· Points of compliance: Boundaries of the Burning Ground· Compliance time frame: Since no immediate threat has been identified, any time within thenext 2-5 years should be protective.2.3 STATE OF INDIANA WASTE MANAGEMENT REQUIREMENTSThe Burning Ground Area sites are expected to be defined as “open dumps” under 329 IAC 10-2-128, and are therefore expected to be regulated under Indiana Administrative Code 329, SolidWaste Land Disposal Facilities (329 IAC 10-4-1 through 329 10-4-4, Open Dumping andDumps). Based on the rules specified in 329 IAC 10-4-4, “The owner of real estate upon whichan open dump is located is responsible for … correcting and controlling any nuisance conditionsthat occur as a result of the open dump. Correction and control of the nuisance conditions mustinclude: removal of all solid waste from the area of the open dump and disposal of such wastes ina solid waste land disposal facility permitted to accept the waste, or other methods approved bythe commissioner…”SECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 2-10The Indiana Administrative Code allows for the Commissioner to approve alternative cleanupmethods besides removal and disposal at a licensed solid waste facility, such as leaving thedebris on site with an approved cover. Under the current rules of 329 IAC 10-22-7 (Final coverrequirements for existing municipal solid waste landfills (MSWLF) units constructed without acomposite bottom liner) the final cover for an unlined landfill must have slopes not less than 4%nor greater than 33%, and the cover must be a composite type consisting of compacted clay,HDPE liner, drainage layer, and vegetative soil layer. The composite cap is required forpermitted, unlined, MSWLFs or MSWLFs without a leachate collection system. Therefore, thecomposite cap does not specifically apply to the Burning Ground Area. Additionally thiscomposite cap requirement is in effect to protect underlying groundwater resources, which arenot present beneath the Burning Ground Area sites. Therefore, a less stringent soil coverdesigned to prevent or minimize direct contact with the debris is considered to be appropriate fordebris left on site.2.4 PROPOSED CORRECTIVE MEASURE OBJECTIVESThe proposed corrective measure objectives for the Burning Ground Area sites are focused oncomplying with Indiana solid waste regulations and reducing the potential risk to human healthwith concurrent protection of ecological receptors and the environment. The proposed correctivemeasure objectives are:· Remove or cover landfill debris to comply with State of Indiana solid waste rules.· Reduce potential human exposures to all COPCs in the upper two feet of soil/sediment withinthe Burning Ground Area. Based on reasonable future land use and human health riskassessment techniques, unacceptable human health risks can be eliminated by controllingexposure to lead to the following media cleanup level:– Lead = 1,700 mg/kg– The ecological risk assessment found that elimination of exposure to the mediacleanup levels listed above would provide significant reduction of exposure potentialswithin the Burning Ground Area.· Control potential migration of all COPECs to off-site receptors that may result from thetransport of contaminated soil and sediment in storm water runoff.TABLE 2-1PARAMETER VALUES USED WITH EPA ADULT LEAD EXPOSURE MODELMETHODOLOGY TO DERIVE ACTION LEVELS FOR LEADCORRECTIVE MEASURE STUDY FOR THE BURNING GROUND AREAQ:\4599\fl010g00\inaap_cms_BG Area Draft\BGCMSTable2-1.doc 1 of 1ModelParameterParameterDescriptionEPA DefaultParameter Values(EPA, 1996) Value Used Units BasisGSDi,adult Individual bloodlead geometricstandard deviation1.8 (homogeneouspopulation)2.1 (heterogeneouspopulation)1.9 unitless A GSDi,adult value of 1.9 was selectedassuming the population is relativelyhomogeneous (approximately 8% of thepopulation is non-white).PbBadult,0.95,goal95th percentileblood leadconcentration inadult-- 25, 30, and 40 mg/dL Based on blood lead levels of concernin adults of 25 (DHHS, 1997), 30(FDA, 1990; Carrington and Bolger,1992; Carrington et al. 1993;ACGIH, 1994; 1999; OSHA, 1991)and 40 mg/dl (OSHA, 1978; WHO,1980).PbBadult,0 Baseline bloodlead concentration1.7 (whites)2.0 (Hispanics)2.2 (blacks)1.8 mg/dL A PbBadult,0 value of 1.8 mg/dl wasselected assuming the population isprimarily white.BKSF Biokinetic slopefactor0.4 0.4 mg/dL per mg uptake/day Based on the EPA TRW analysis ofPocock et al. (1983) and Sherlock et al.(1984) data (EPA, 1996).IRs Soil ingestion rate -- 0.100 g/day Site-specific value for adult receptorsAFs Oral absorption oflead in soil0.12 0.05 unitless Based on site-specific knowledge oflead particle size and source.EFs Exposurefrequency-- 40 (construction worker)48 (site worker)48 (adult recreational receptor)48 (child recreational receptor)days/year Site-specific valuesAT Averaging time -- 56 (construction worker)350 (commercial fisherman)350 (adult recreational receptor)350 (child recreational receptor)days/year Site-specific valuesTABLE 2-2CHEMICALS OF POTENTIAL ECOLOGICAL CONCERN ANDPRELIMINARY RISK BASED CONCENTRATIONSBURNING GROUND AREAOrganic COPECsPRBC(μg/L)Receptor orBackground(1) Organic COPECsPRBC(ug/kg)Receptor orBackground(1)Bis(2-ethylhexyl) phthalate 54.0 Amphibians 2,4-Dinitrotoluene 230 BenthosTotal LMWPAHs 1,200 BenthosAnthracene 845 BenthosPhenanthrene 1,170 BenthosTotal HMWPAHs 2,300 BenthosBenzo(a)anthracene 1,050 BenthosBenzo(a)pyrene 1,450 BenthosBenzo(b)fluoranthene 160 BenthosBenzo(g,h,i)perylene 250 BenthosBenzo(k)fluoranthene 160 BenthosChrysene 1,290 BenthosFluoranthene 2,230 BenthosIndeno(1,2,3-c,d)pyrene 240 BenthosPyrene 1,520 Benthos4,4-DDE 62.9 BenthosEndosulfan sulfate 1.09 BenthosInorganic COPECs (μg/L) Inorganic COPECs (mg/kg)Aluminum 460 Plants Antimony 8.66 BackgroundAntimony 640 Plants Arsenic 48.0 BenthosBarium 60.3 Background Chromium 120 BenthosCalcium 116,000 Invertebrates Copper 100 BenthosChromium 44 Invertebrates Iron 250,000 BenthosCopper 11.3 Background Lead 82.0 BenthosIron 158 Invertebrates Manganese 13,294 BackgroundLead 18.9 Amphibians Nickel 70.0 BackgroundManganese 1,100 Invertebrates Zinc 540 BenthosMercury 0.230 AmphibiansNickel 25.2 BackgroundSilver 0.120 AmphibiansThallium 57.0 AmphibiansZinc 40.7 Background(1) When the PRBC is below INAAP upland soil background levels, the PRBC becomes the background levelNotes:COPEC = Chemical of potential ecological concernPRBC = Preliminary risk based concentrationTotal LMWPAHs = Sum of the low molecular weight (<200 daltons) polycyclic aromatic hydrocarbonsTotal HMWPAHs = Sum of the high molecular weight (>200 daltons) polycyclic aromatic hydrocarbonsSurface Water Surface SedimentQ:\4599\fl010g00\inaap_cms_BG Area Draft\BGCMSTables_rev1.xls Page 1 of 2 10/13/03TABLE 2-2CHEMICALS OF POTENTIAL ECOLOGICAL CONCERN ANDPRELIMINARY RISK BASED CONCENTRATIONSBURNING GROUND AREAOrganic COPECsPRBC(μg/kg)Receptor orBackground(1) Organic COPECsPRBC(μg/kg)Receptor orBackground(1)Toluene 3,000 Plants Terrestrial FoodwebN-nitrosodiphenylamine 20,000 Invertebrates Carbon Tetrachloride 8,253 ShrewPhenol 79,000 Plants Tetrachloroethylene 48,038 ShrewAnthracene 20,000 Plants Trichloroethylene 444,188 ShrewNaphthalene 850,000 Plants 2,4-Dinitrotoluene 517 ShrewPhenanthrene 5,000 Plants 1,3-Dinitrobenzene 630 ShrewBenzo(a)pyrene 8,800,000 Plants N-Nitrosodiphenylamine 21,577 ShrewFluoranthene 10,000 Plants Phenanthrene 21,142 ShrewPyrene 10,000 Plants Total HMWPAHs 2,623 ShrewTotal DDT 47.1 WoodcockAldrin 0.142 WoodcockDieldrin 5.68 ShrewEndrin 7.25 Gray BatTotal Heptachlor 379 ShrewTotal PCBs 22.4 Gray BatAquatic Foodweb2,4-Dinitrotoluene 23,632 Gray Batbis(2-ethylhexyl) phthalate 10,243 SnipeTotal HMWPAHs 31,603 SnipeTotal DDT 265 SnipeTotal Chlordane 39,596 Gray BatInorganic COPECs (mg/kg) Inorganic COPECs (mg/kg)Aluminum 28,958 Background Terrestrial FoodwebAntimony 8.66 Background Lead 39.4 BackgroundArsenic 23.7 Background Zinc 198 BackgroundBarium 415 Background Aquatic FoodwebBeryllium 10.0 Plants Copper 1,061 Gray BatCadmium 44.0 Plants Mercury 1.13 SnipeChromium 107 Plants Zinc 4,263 SnipeCobalt 50.0 PlantsCopper 210 PlantsCyanide 1.80 PlantsLead 1,433 PlantsMercury 96.0 PlantsNickel 100 PlantsSelenium 10.0 PlantsSilver 2.00 PlantsThallium 5.17 BackgroundVanadium 207 PlantsZinc 400 Plants(1) When the PRBC is below INAAP upland soil background levels, the PRBC becomes the background levelNotes:COPEC = Chemical of potential ecological concernPRBC = Preliminary risk based concentrationTotal LMWPAHs = Sum of the low molecular weight (<200 daltons) polycyclic aromatic hydrocarbonsTotal HMWPAHs = Sum of the high molecular weight (>200 daltons) polycyclic aromatic hydrocarbonsSurface Soil FoodwebQ:\4599\fl010g00\inaap_cms_BG Area Draft\BGCMSTables_rev1.xls Page 2 of 2 10/13/03Develop media cleanup levels that will beprotective of both human health and ecologicalreceptorsEvaluate Corrective Measure Alternatives usingthese media cleanup levelsYesDRN BY:JJSPROJ #45FL99010G.00DATE:01/11/02REVISION:DECISION DIAGRAM FORDEVELOPMENT OF MEDIA CLEANUPLEVELSBURNING GROUND AREAINDIANA ARMY AMMUNITION PLANTFIG. NO:Evaluate human health risk-based media cleanup level data set for ecological receptors:1. Censor all samples using proposed indicator chemicals and proposed media cleanup levels2. Replace all inorganic data in censored samples with background concentrations for each COPEC3. Replace all organic data in censored samples with one-half reporting limit values for each COPECEvaluate exposure (risk)reductions:Are all COPEC exposure potentialsreduced?No Select alternatechemical data setYesEvaluate significance ofresidual risks of all COPECs:Are all risks reduced to anacceptable level?Does the site pose arisk to human health?YesSelect chemicals of concernthat contribute to exceedanceof non-carcinogenic HI > 1.0and/or carcinogenic risk> 1x10-5Calculate a cleanup levelbased on a target HI = 1.0 for non-carcinogensand/or a target risk of 1x10-5for carcinogens using appropriate scenariosand receptorsCalculate residualhuman health riskwith cleanup levelincorporatedWill allhuman health risksbe reduced toacceptablelevels?No Re-evaluate chemicalsof concernNoNo Further Actionrequired for humanhealth receptors2-1YesNo1. Calculate environmental exposure concentrations for all COPEC using censored data sets2. Calculate all hazard quotients for all COPECs and relevant ecological receptorsq:\4599\fl010g00\inaap_cms_bg area draft\riskflow.vsdSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-1This section presents the development of remedial technologies and assembly of technologiesinto corrective measure alternatives.3.1 CORRECTIVE MEASURE APPROACH3.1.1 Range of Potential Corrective MeasuresThe proposed corrective measure objective developed in the previous section is aimed atprotection of human health for reasonable future land use (i.e., commercial/industrial), withconcurrent protection of ecological receptors. In order to achieve the proposed correctivemeasure objective, this CMS will consider the following range of potential corrective measures:· Institutional Controls: Restrict public access to the site through land use restrictions.· Engineering Controls: Implement physical controls (e.g., fencing, protective covers/caps, orremoval) to limit potential exposure to contaminated media and/or migration of contaminatedmedia.· Treatment: Use in situ or ex situ treatment technologies to reduce the toxicity, mobility,and/or volume (TMV) of contaminants.· Monitoring: Monitor the sites to ensure that the health and/or environmental protectionachieved by the corrective action is maintained.3.1.2 Site Characteristics that Affect Design and Construction of a Corrective MeasureThe corrective actions listed above may be implemented alone or in combination. Based on thecorrective action objectives and information obtained during the Phase I RI and Phase II RFI, thefollowing site-specific characteristics are considered to be relevant to the design and constructionof a corrective measure at the Burning Ground Area.3.1.2.1 Protection of Endangered SpeciesThe ecosystem along the Jenny Lind Run supports the gray bat, a Federally listed endangeredspecies. The gray bat uses caves in the Jenny Lind Run. An Endangered Species ManagementPlan and Environmental Assessment (ESMP/EA) for the Gray Bat, Myotis grisescens has beencompleted (Tetra Tech, draft final, December 1999). The ESMP/EA developed managementobjectives, conservation goals, and prescriptions for the Jenny Lind Run drainage basin. Themanagement prescriptions relevant to this project include:· Incorporating gray bat habitat conservation guidelines into existing INAAP activities thatmight impact the gray bat, including environmental remediation· Protecting karst features and water quality, by:– Prohibiting earth-moving activities and disturbance to natural vegetation within 100feet of a karst featureSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-2– When earth-moving activities are done more than 100 feet from a karst feature butwithin the drainage area of the karst feature, use appropriate erosion control measuresto prevent debris from entering the karst feature· If deviations from the management prescriptions are necessary, ESA Section 7 consultationwith USFWS Region 3 Bloomington Field Office is necessary to avoid or minimize impactson the gray bat.Earthwork activities associated with corrective action, such as clearing and grubbing, placing fill,or excavating and stockpiling materials, would be considered a possible disturbance of the graybat habitat. It is not likely, but is possible, that the gray bat forages within the Burning GroundArea, so disturbance of forest could be an issue. However, erosion of soil/sediment could impactdownstream water quality.There is evidence based upon soil borings and an Aerial Photogeologic Analysis (ERI, 1995) thatkarst features are present in subsurface of the Burning Ground Area. From field reconnaissance,karst features were not present at the surface, nor was there any evidence (i.e. sinkholes) thatsubsurface karst features are near the surface. Therefore, for this CMS, The Burning GroundArea is not considered to be in a karst feature, but it does drain into the Jenny Lind Pond.Earthwork activities should use special erosion control measures to minimize any disruption todowngradient drainage and possibly caves. Based on the management prescriptions and locationof contaminated media, ESA Section 7 consultation is required for any corrective actioninvolving containment, removal, or treatment at the Burning Ground Area.3.1.2.2 Areas and Volumes of Affected MediaThe estimated areas of landfill debris are shown on Figure 3-1. Soil and sediment containinglead above the media cleanup levels are included in the area and volume calculations. Thecombined landfill debris and contaminated media is defined as affected media.The estimated areas of affected media were interpreted using the chemical data set whichincludes 156 surface soil and sediment samples as part of 261 total soil samples collected at theBurning Ground Area. The estimated volumes of affected media are based on the analyticalresults and visual examination of recovered samples from the 106 borings and 29 test pitscompleted at the Burning Ground Area. The volume of contaminated media is segregated intothe following categories:· Soil and sediment that contain lead at concentrations above the media cleanup levels· Debris, including any surface soil over the debrisFor soil and sediment volume estimates, the depth of contamination was assumed to be 2 feetbelow ground surface. For the debris volume estimate, the depth of debris was averaged basedon the depths of debris encountered at the various borings and test pits. The depths of debris arenoted on Figure 3-1.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-3Site Estimated Area Estimated VolumeSite 26 1.2 acres 13,000 cySite 27 0.5 acres 100 cySite 28 0.1 acres 470 cySite 34 0.2 acres 100 cy*Site 46 3.7 acres 14,000 cySite 56 0.1 acres 150 cySite 59 1.9 acres 10,000 cySite 60 4.0 acres 41,000 cyBurning Ground Area 11.7 acres 79,000 cy*This amount is estimated (only surface soil samples were collected).The total area to be capped or covered in the Burning Ground Area is 12.4 acres, which is greaterthan the sum of the Burning Ground Area sites. This is due to the small areas between sites thatwill be capped or covered.3.1.2.3 Contaminant CharacteristicsThe lead present at the Burning Ground Area is believed to be derived from the formerlandfilling, burning, and lead melting operations that took place at this site. Lead is a metal witha specific gravity of 11.35 and is generally insoluble (0.2-1%) at normal pH, but its solubilityincreases when pH is below 5. Lead will form complexes with organic matter and clay mineralsin the environment.If contaminated media (i.e., soil/sediment with lead at concentrations above media cleanuplevels) are excavated as part of the corrective measure, some of the media may either be found tobe characteristically hazardous or may contain chemicals at high enough concentrations toprevent disposal as a “special waste” in the local landfill. The contaminated media have notbeen tested using the toxicity characteristic leaching procedure (TCLP); however, assuming the“20 times rule” suggests that some of the material may be found to be characteristicallyhazardous. Therefore, corrective measure activities that involve removal of contaminated mediaassume that 20 percent of the contaminated media will be handled and disposed of as ahazardous waste.3.2 IDENTIFICATION AND SCREENING OF POTENTIAL TECHNOLOGIES3.2.1 Initial Screening of Technologies and Process OptionsCandidate remedial technologies and process options (process options include various methodsof implementing a remedial technology) have been reviewed for applicability at the BurningGround Area. Technologies and process options that are not technically feasible or do not applyto the site conditions and chemicals detected at the site have been screened out.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-4The evaluation of applicability takes into consideration the practical nature of implementation,given the physical site conditions (e.g., location configuration and topography) and the waste orchemical characteristics (e.g., chemical types and extent). Remedial technologies and processoptions that are considered to be potentially applicable, based on the initial screening, are listedin Table 3-1.3.2.2 Final Screening of Technologies and Process OptionsThe potentially applicable process options were further evaluated and screened to narrow thefield of potential options to a single (if possible) representative technology or process option foreach general corrective measure category.3.2.2.1 Screening Criteria for Process OptionsThe criteria for screening of process options consisted of effectiveness, implementability, andcost, as described below.EffectivenessThe evaluation of a technology’s effectiveness focuses on three primary considerations:· Ability to handle the estimated volumes of contaminated media and to meet correctivemeasure objective· Potential effects on human health and the environment during implementation· Reliability and proven performance with respect to site conditions and chemicals of potentialconcernImplementabilityThe evaluation of implementability includes consideration of the technical and administrativefeasibility of a process option. Implementability is characterized as readily implemented,moderately difficult, or difficult to implement relative to other process options underconsideration, based on experience and engineering judgment. The following factors wereconsidered as part of the implementability evaluation:· Availability and capacity of treatment, storage, and disposal facilities· Availability of equipment and trained workers needed to implement the technologyCostThe cost evaluation was limited to a qualitative cost comparison that considers the capital andoperation, maintenance, and monitoring (OM&M) costs of a particular process option. Costswere characterized as low, moderate, or high, based on engineering judgment and experience.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-53.2.2.2 Summary of Screening ResultsThe evaluation and screening process is presented in Table 3-2. Comments regardingeffectiveness, implementability, and relative cost are also provided in the table. Technologiesare identified as retained or not retained and screening comments are provided to justify theexclusion of certain process options. Some of the process options cannot be used as stand-alonetechnologies, but have been retained for use with another technology. The followingtechnologies were retained for assembly into corrective measure alternatives:Potential Corrective Measure Representative TechnologiesInstitutional Controls Land Use RestrictionsEngineering Controls through Containment Grading, Revegetation, Soil Cover, andComposite CapEngineering Controls through Removal and Landfilling Excavation and Disposal at RCRA Subtitle Dor C Landfill.Monitoring and Inspection Periodic Soil, Sediment and Surface WaterSampling and Site Inspections3.3 IDENTIFICATION OF CORRECTIVE MEASURE ALTERNATIVESCorrective measure alternatives (CMAs) were developed using the technologies and processoptions that passed through the above screening process. Nine potential CMAs have beenidentified, as described in the following subsections.3.3.1 CMA-1, No ActionThis alternative assumes that no further corrective action would be implemented at the BurningGround Area. Human health and ecological risks would be those identified in the respectivebaseline risk assessments presented in the Phase II RFI report (URS, 2001). This alternativeserves as a baseline to which other alternatives can be compared.3.3.2 CMA-2, Institutional Controls and Monitoring3.3.2.1 Description of CMA-2CMA-2 involves using institutional controls to restrict land use at the site and monitoring totrack potential changes in the location or level of contaminants to help make future riskmanagement decisions. The proposed institutional controls and monitoring include:· Land use restrictions on the site· Completing a baseline inventory of the site and annually monitoring the siteInstitutional controls have already been implemented at the site in the form of State legislationthat restricts the future land use to agricultural, commercial, industrial, or State park. BecauseSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-6this alternative would leave the existing contamination at the surface, it is assumed that a formaldeed restriction to prevent construction activities would be implemented.The proposed monitoring would include a one-year, quarterly baseline inventory to develop adatabase for statistical analysis of current site conditions. Annual monitoring and site visitswould then be needed to assure that site conditions were relatively static. This would includedownstream sediment and surface water samples to evaluate potential off-site migration. Longterm surface water and sediment monitoring would effectively document the migration of thosemedia. Surface water and sediment monitoring would help to provide early warning of potentialfuture increased exposure potential. A five-year review of the site and controls would be used toassess the effectiveness of this option and make future risk management decisions.3.3.2.2 Effectiveness-of CMA-2Restrictions on current and future land use are expected to decrease potential human exposureand subsequent health risk from exposure to contaminated surface soil and sediment. However,land use restrictions have no effect on reduction of potential exposures to ecological receptors.Restrictions on earth moving activities within the site boundaries are expected to limitdisturbance to contaminated media and subsequent migration through erosion. Monitoring is aneffective risk management tool for tracking and evaluating the effect of potential futurecontaminant migration.3.3.2.3 Implementability-of CMA-2The institutional actions described above are expected to present minimal technical andadministrative difficulties. Long-term administrative oversight is required to maintain the landuse restriction and oversee monitoring. Coordination with the IDEM is required during theplanning and reporting phases of the alternative.3.3.3 CMA-3, Removal and Disposal3.3.3.1 Description of CMA-3CMA-3 involves removing the landfill debris and contaminated media (i.e., soil and sedimentfound at levels above the media cleanup levels) and transporting it to a permitted solid waste(Subtitle D) or hazardous waste (Subtitle C) landfill. The final disposal location would dependon waste characterization completed at the time of removal. This alternative would eliminateexposure potentials caused by direct contact or migration of contaminated media, as well assatisfy IDEM solid waste regulations. Following a short-term monitoring program to confirmremoval objectives have been achieved, no additional institutional controls and monitoringwould be necessary. The proposed removal and disposal activities include:· Removal of all landfill debris as well as contaminated media (i.e., soil/sediment found atconcentrations above media cleanup levels)· Disposal of removed landfill debris and contaminated media in a permitted landfill· Grading, reseeding and establishing vegetationSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-7A conceptual plan with depths of debris to be excavated is shown on Figure 3-1.Prior to removal, the site would first be cleared and grubbed. Cleared vegetation can be mulchedand reused during the establishment of final vegetative cover used for slope stabilization.Materials would be removed to a depth where contamination is determined to be below mediacleanup standards. Typically, testing for this is done by developing a grid across thecontaminated area and collecting samples from known grid cell locations. The grid cells aregenerally sized based on a balance of cost versus the acceptable statistical accuracy andprecision. The estimated volume of media to be removed is 79,000 cubic yards with anestimated weight of 119,000 tons. Removal of the contaminated media would be done usingconventional earth moving equipment. Erosion control measures for storm water and windwould be required during all activities that disturb contaminated media.It has been assumed that 80 percent of the contaminated media would be handled as Subtitle Dsolid waste while the remaining 20 percent of contaminated media would be handled as SubtitleC hazardous waste. The Subtitle D solid waste can be transported to the local RCRA Subtitle Dlandfill (i.e., Floyd Clark landfill) for disposal. The Floyd Clark landfill is located in Clarksville,Indiana, about 20 miles from the site. The Subtitle C hazardous waste can be transported to thenearest Subtitle C landfill, which is located in Roachville, Indiana.After the removal and successful confirmatory sampling has been completed, some grading andslope stabilization would be done to protect the site from excessive erosion. The surface wouldbe vegetated with grasses and shrubs native to the area with special consideration given to long-termerosion control. Because of the varied depths of excavation (up to 15 feet below existinggrade), several small ponds may form over several portions of the Burning Ground Area. Areasof flow concentration, such as drainage channels and outlets from any deeper excavations whereponds may form, would be finished with a gravel and rip-rap lining designed to minimize erosionand sediment transport. An alternate approach (which is not included in the cost estimate for thisalternative) would be to import soil and develop positive drainage through the entire site.3.3.3.2 Effectiveness-of CMA-3The removal of contaminated media would eliminate potential exposures and associatedecological and human health risks as well as potential future migration. Complete removal ofdebris and contaminated media would also eliminate the need for long-term monitoring at theBurning Ground Area.Disposal of the landfill debris and contaminated media in a licensed landfill is expected to be asafe and effective means for permanent control of the material. However, the Army would retainthe long-term liability for the waste, which may include some financial risk if the licensedlandfill leaks and causes environmental or human health risks that require investigation and/orremediation.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-83.3.3.3 Implementability-of CMA-3The activities proposed for CMA-3 are expected to present minimal technical and administrativedifficulties. Because all the contaminated media and landfill debris are removed from the site,long-term administrative oversight is not required. Coordination with the IDEM is requiredduring the planning, construction, and reporting phases of this alternative.The construction activities associated with CMA-3 can be implemented using traditionalconstruction techniques and earth moving equipment. Possible complications are expected to beassociated with excavating into mixed/unknown debris, removing materials from karst features,and the potentially steep slopes. The required equipment, manpower, and materials are locallyavailable. Special considerations will be needed to control erosion caused by storm flows andwind during construction. OSHA 29 CFR 1910.120 (Hazwopper) trained construction workerswill be required during activities that involve direct contact with contaminated media, such asexcavation and grading.3.3.4 CMA-4, Composite Cap with Institutional Controls and Monitoring3.3.4.1 Description of CMA-4CMA-4 involves containing the contaminated media and landfill debris by installing a compositecap over the material. This will reduce the potential for direct exposures to both human andecological receptors and control migration of contaminated media that may be caused by erosionand sediment transport. The institutional controls and monitoring discussed for CMA-2 will alsobe part of this alternative. The proposed containment activities include:· Regrading areas of the site to develop slopes and grades more suitable for control of runoffand placement of the cap· Installing a composite cap· Reseeding and establishing vegetationA conceptual plan of the proposed composite cap area is shown on Figure 3-2. A conceptualsection of the composite cap is shown on Figure 3-3. The area to be capped is about 12.4 acres.Initially, the site would be cleared of existing vegetation to prepare the site for the compositecap. Large tree roots would be grubbed. Vegetation can be mulched and reused during theestablishment of final vegetative cover. At this time, any surface debris would be consolidatedand graded over the area to be capped. The entire area to be capped would be graded to establisheven slopes between 4 percent and 33 percent. This would also include grading any debris that isin or near drainages away from the drainage to reduce the transport of sediments downstream.During this time, Site 28 would be graded onto Site 26 due to the site’s location along a drainageand small footprint. Since grading would likely involve disturbance of contaminated media,erosion control measures including dust control would be required. Excavated materials that arenot contaminated would be included in the overall earthwork balance and used in the sitegrading.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-9A locally available cohesive soil from within the INAAP property would be imported for use inthe composite cap. The cap would be constructed by first placing a 12 inch layer of compactedclay over the contaminated media and debris. A 30-mil HDPE liner would then be placed overthe compacted clay layer, the seams heat welded, and testing of the welded seams would assurethat the liner is impermeable. On top of the liner, a 12 inch layer of sand will be used fordrainage. A geotextile would be placed on top of the sand to act as a filter for the protective soilcover that is placed over the sand. The protective soil cover would be placed to a final thicknessof at least 2 feet. The surface would be graded to provide positive drainage and the upper 6inches would be tilled and planted. Depending on the soil characteristics, amendments andnutrients may be added before tilling to improve the soil’s fertility. The surface would bevegetated with grasses and shrubs native to the area with special consideration given to long-termerosion control.The finished composite cap surface would be sloped a minimum of 4% and a maximum of 33%.Rip-rap would be placed along the toes of any steep slopes and along drainage channels used tocollect and route surface runoff away from the capped areas. Constructed drainage channelswould direct runoff to the nearest available natural drainage.3.3.4.2 Effectiveness-of CMA-4The composite cap would decrease potential exposures to contaminated media and subsequentlyreduce potential ecological and human health risks. A composite cap would also limit thepotential for migration of contaminated media caused by erosion and sedimentation processes.Periodic site inspections and maintenance of the composite cap, in conjunction with the surfacewater and sediment sampling described under CMA-2, are expected to be necessary to maintainthe effectiveness of this alternative.3.3.4.3 Implementability-of CMA-4The activities proposed for CMA-4 are expected to present minimal technical and administrativedifficulties. Long-term administrative oversight is required to maintain the land use restrictionand oversee monitoring and maintenance of the constructed improvements. After approval bythe commissioner, coordination with the IDEM is required during the planning, construction, andreporting phases of this alternative.The construction activities associated with CMA-4 can be implemented using traditionalconstruction techniques and earth moving equipment. The required equipment, manpower, andmaterials are locally available. Special considerations will be needed to control erosion causedby storm flows and wind during construction. OSHA 29 CFR 1910.120 (Hazwopper) trainedconstruction workers will be required during activities that involve direct contact withcontaminated media, such as compositing, grading and initial placement of the composite cap.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-103.3.5 CMA-5, Soil Cover with Institutional Controls and Monitoring3.3.5.1 Description of CMA-5CMA-5 involves containing the contaminated media by installing a vegetated soil cover over thematerial. This will reduce the potential for direct exposures to both human and ecologicalreceptors and control migration of contaminated media that may be caused by erosion andsediment transport. The institutional controls and monitoring discussed for CMA-2 will also bepart of this alternative. The proposed containment activities include:· Regrading areas of the site to develop slopes and grades more suitable for control of runoffand placement of a soil cover· Installing a vegetated soil cover· Reseeding and establishing vegetationA conceptual plan of the proposed soil cover area is shown on Figure 3-2. A conceptual sectionof the soil cover is shown on Figure 3-3. The area to be covered is about 12.4 acres.The site would be prepared the same as described above for CMA-4. A locally availablecohesive soil from within the INAAP property would be imported for use as the soil cover. Thelower 18 inches of the soil cover would be compacted, and the upper 6 inches would be tilledand planted with locally hardy vegetation. Final grades would be between 4 percent and 33percent. Erosion control measures, such as rip-rap, would be used along the toe of steepembankments and along drainage channels that collect and route surface runoff.3.3.5.2 Effectiveness-of CMA-5The soil cover would decrease potential exposures to contaminated media and subsequentlyreduce potential ecological and human health risks. A soil cover would also limit the potentialfor migration of contaminated media caused by erosion and sedimentation processes. Periodicsite inspections and maintenance of the vegetated cover, in conjunction with the surface waterand sediment sampling described under CMA-2, are expected to be necessary to maintain theeffectiveness of this alternative.3.3.5.3 Implementability-of CMA-5The activities proposed for CMA-5 are expected to present minimal technical and administrativedifficulties. Long-term administrative oversight is required to maintain the land use restrictionand oversee monitoring and maintenance of the constructed improvements. After approval by thecommissioner, coordination with the IDEM is required during the planning, construction, andreporting phases of this alternative.The construction activities associated with CMA-5 can be implemented using traditionalconstruction techniques and earth moving equipment. The required equipment, manpower, andmaterials are locally available. Special considerations will be needed to control erosion causedby storm flows and wind during construction. OSHA 29 CFR 1910.120 (Hazwopper) trainedSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-11construction workers will be required during activities that involve direct contact withcontaminated media, such as grading and initial placement of the soil cover.3.3.6 CMA-6, Consolidation and Composite Cap with Institutional Controls andMonitoring3.3.6.1 Description of CMA-6CMA-6 involves consolidating the debris from Sites 46 and 59 to Sites 26, 27, 28, 34, 56, and 60followed by installing a composite cap over the debris and contaminated media. Sites 46 and 59were chosen because of the location of the sites next to drainages and the steep slopes that occurat the two sites. By removing the debris at these sites the debris would be eliminated from thesites and would reduce the amount of area that would need to be capped. This action wouldreduce the potential for direct exposures to both human and ecological receptors and controlmigration of contaminated media that may be caused by erosion and sediment transport. Theinstitutional controls and monitoring discussed for CMA-2 will also be part of this alternative.The proposed containment activities include:· Consolidation of debris from Sites 46 and 59· Regrading areas of the site to develop slopes and grades more suitable for control of runoff· Installing a composite cap· Reseeding and establishing vegetationA conceptual section of the composite cap is shown on Figure 3-3. A conceptual plan of theconsolidated area and the proposed composite cap is shown on Figure 3-4.. The area to becapped is about 6.8 acres and the volume to be consolidated is about 24,000 cubic yards.The Burning Ground Area sites would be cleared of existing vegetation, then large tree rootswould be grubbed out. The fill and debris would then be removed from Sites 46 and 59 withconventional earthmoving equipment. The debris would be loaded onto dump trucks andtransported to Sites 26, 27, 34, and 56 located in the central portion of the Burning Ground Area.The debris would be spread out and compacted, the area would be pre-graded, including gradingany debris that is in or near drainages away from the drainage to reduce the transport ofsediments downstream. During this time, Site 28 would be graded onto Site 26 due to the site’slocation along a drainage and small footprint. The area would then be capped according to themethods described for CMA-4. It is assumed that 20% of the debris removed from Sites 46 and59 would be considered hazardous and would be transported and disposed of in a RCRA SubtitleC facility.3.3.6.2 Effectiveness-of CMA-6Consolidation of debris would reduce the area that would need to be capped. The composite capwould decrease potential exposures to contaminated media and subsequently reduce potentialecological and human health risks. A composite cap would also limit the potential for migrationof contaminated media caused by erosion and sedimentation processes. Periodic site inspectionsSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-12and maintenance of the composite cap, in conjunction with the surface water and sedimentsampling described under CMA-2, are expected to be necessary to maintain the protectiveness ofthis alternative.3.3.6.3 Implementability-of CMA-6The activities proposed for CMA-6 are expected to present minimal technical difficulties.Possible complications are expected to be associated with excavating into mixed/unknowndebris, removing materials from karst features, and the potentially steep slopes. The handlingand redepositing debris may not be allowable under IDEM solid waste rules unless all currentsolid waste requirements are met. Long-term administrative oversight is required to maintain theland use restriction and oversee monitoring and maintenance of the constructed improvements.After approval by the commissioner, coordination with the IDEM is required during theplanning, construction, and reporting phases of this alternative.The construction activities associated with CMA-6 can be implemented using traditionalconstruction techniques and earth moving equipment. The required equipment, manpower, andmaterials are locally available. Special considerations will be needed to control erosion causedby storm flows and wind during construction. OSHA 29 CFR 1910.120 (Hazwopper) trainedconstruction workers will be required during activities that involve direct contact withcontaminated media, such as compositing, grading and initial placement of the composite cap.3.3.7 CMA-7, Consolidation and Soil Cover with Institutional Controls and Monitoring3.3.7.1 Description of CMA-7CMA-7 is the same as CMA-6 except that a soil cover (instead of a composite cap) would beinstalled over the debris. This action would reduce the potential for direct exposures to bothhuman and ecological receptors and to control migration of contaminated media that may becaused by erosion and sediment transport. The institutional controls and monitoring discussedfor CMA-2 will also be part of this alternative. The proposed containment activities include:· Consolidation of the fill and debris from Sites 46 and 59· Regrading areas of the site to develop slopes and grades more suitable for control of runoff· Installing a vegetated soil cover· Reseeding and establishing vegetationA conceptual section of the soil cover is shown on Figure 3-3. A conceptual plan of theconsolidated area and the proposed soil cover is shown on Figure 3-4. The area to be covered isabout 6.8 acres and the volume to be consolidated is about 24,000 cubic yards.The Burning Ground Area sites would be cleared of existing vegetation, then large tree rootswould be grubbed out. The fill and debris would then be removed from Sites 46 and 59 withconventional earthmoving equipment. The debris would be loaded onto dump trucks andtransported to Sites 26, 27, 34, and 56 located in the central portion of the Burning Ground Area.The debris would be spread out and compacted, the area would be pre-graded, including gradingSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-13any debris that is in or near drainages away from the drainage to reduce the transport ofsediments downstream. During this time, Site 28 would be graded onto Site 26 due to the site’slocation along a drainage and small footprint. A soil cover would be installed according to themethods described for CMA-5. It is assumed that 20% of the debris removed from Sites 46 and59 would be considered hazardous and would be transported and disposed of in a RCRA SubtitleC facility.3.3.7.2 Effectiveness-of CMA-7Consolidation of debris would reduce the area required for the soil cover. The soil cover woulddecrease potential exposures to contaminated media and subsequently reduce potential ecologicaland human health risks. A soil cover would also limit the potential for migration ofcontaminated media caused by erosion and sedimentation processes. Periodic site inspectionsand maintenance of the composite cap are expected to be necessary to maintain theprotectiveness of this alternative. Periodic site inspections and maintenance of the vegetatedcover, in conjunction with the surface water and sediment sampling described under CMA-2, areexpected to be necessary to maintain the protectiveness of this alternative.3.3.7.3 Implementability-of CMA-7The activities proposed for CMA-7 are expected to present minimal technical difficulties.Possible complications are expected to be associated with excavating into mixed/unknowndebris, removing materials from karst features, and the potentially steep slopes. The handlingand redepositing debris may not be allowable under IDEM solid waste rules unless all currentsolid waste requirements are met. Long-term administrative oversight is required to maintain theland use restriction and oversee monitoring and maintenance of the constructed improvements.After approval by the commissioner, coordination with the IDEM is required during theplanning, construction, and reporting phases of this alternative.The construction activities associated with CMA-7 can be implemented using traditionalconstruction techniques and earth moving equipment. The required equipment, manpower, andmaterials are locally available. Special considerations will be needed to control erosion causedby storm flows and wind during construction. OSHA 29 CFR 1910.120 (Hazwopper) trainedconstruction workers will be required during activities that involve direct contact withcontaminated media, such as grading and initial placement of the soil cover.3.3.8 CMA-8, Partial Removal/Disposal and Composite Cap with Institutional Controlsand Monitoring3.3.8.1 Description of CMA-8CMA-8 involves removing and disposing contaminated media and debris from Sites 46 and 59,and containing the contaminated media and landfill debris at Sites 26, 27, 28, 34, and 56 with acomposite cap. Sites 46 and 59 were chosen because of the location of the sites next to drainagesand the steep slopes that occur at the two sites. By removing the debris at these sites the debriswould be eliminated and would reduce the area to be capped. This action would eliminateSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-14potential exposures to contaminated media at Sites 46 and 59, with the composite cap at theremaining sites would reduce the potential for direct exposures to both human and ecologicalreceptors and to control migration of contaminated media that may be caused by erosion andsediment transport. The institutional controls and monitoring discussed for CMA-2 will also bepart of this alternative. The proposed containment activities include:· Removal and disposal of contaminated media and debris from Sites 46 and 59· Regrading areas of the site to develop slopes and grades more suitable for control of runoff· Installing a composite cap· Reseeding and establishing vegetationA conceptual section of the composite cap is shown on Figure 3-3. A conceptual plan of theproposed removal area and composite cap is shown on Figure 3-4. The area to be capped is 6.8acres and the volume to be disposed of is about 24,000 cubic yards.The Burning Ground Area sites would be cleared of existing vegetation, then large tree rootswould be grubbed out. The fill and debris would then be removed from Sites 46 and 59 withconventional earthmoving equipment. The debris would be loaded onto dump trucks andtransported to the nearest RCRA Subtitle D facility. It is assumed that 20% of the debrisremoved from Sites 46 and 59 would be considered hazardous and would be transported anddisposed of in a RCRA Subtitle C facility. Sites 26, 27, 28, 34, and 56 would be prepared andcapped according to the methods described in CMA-4.3.3.8.2 Effectiveness-of CMA-8The removal of contaminated media would eliminate potential exposures and associatedecological and human health risks as well as potential future migration. Partial removal of debrisand contaminated would partially, but not completely, eliminate the need for long-termmonitoring at the Burning Ground Area. Disposal of the contaminated media in a licensedlandfill is expected to be a safe and effective means for permanent control of the material.However, the Army would retain the long-term liability for the waste, which may include somefinancial risk if the landfill leaks and causes environmental or human health risks that requireinvestigation and/or remediation.The composite cap would decrease potential exposures to contaminated media and subsequentlyreduce potential ecological and human health risks. A composite cap would also limit thepotential for migration of contaminated media caused by erosion and sedimentation processes.Periodic site inspections and maintenance of the composite cap are expected to be necessary tomaintain the protectiveness of this alternative.3.3.8.3 Implementability-of CMA-8The activities proposed for CMA-8 are expected to present minimal technical and administrativedifficulties. Possible complications are expected to be associated with excavating intomixed/unknown debris, removing materials from karst features, and the potentially steep slopes.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-15Long-term administrative oversight is required to maintain the land use restriction and overseemonitoring and maintenance of the constructed improvements. After approval by thecommissioner, coordination with the IDEM is required during the planning, construction, andreporting phases of this alternative.The construction activities associated with CMA-8 can be implemented using traditionalconstruction techniques and earth moving equipment. The required equipment, manpower, andmaterials are locally available. Special considerations will be needed to control erosion causedby storm flows and wind during construction. OSHA 29 CFR 1910.120 (Hazwopper) trainedconstruction workers will be required during activities that involve direct contact withcontaminated media, such as compositing, grading and initial placement of the composite cap.3.3.9 CMA-9, Partial Removal/Disposal and Soil Cover with Institutional Controls andMonitoring3.3.9.1 Description of CMA-9CMA-9 involves removing and disposing contaminated media and debris from Sites 46 and 59,and containing the contaminated media and landfill debris at Sites 26, 27, 28, 34, and 56 with asoil cover. Sites 46 and 59 were chosen because of the location of the sites next to drainages andthe steep slopes that occur at the two sites. By removing the debris at these sites the debriswould be eliminated and the size of the area to be covered would be reduced. This action wouldeliminate potential exposures to contaminated media at Sites 46 and 59, with the soil cover at theremaining sites would reduce the potential for direct exposures to both human and ecologicalreceptors and to control migration of contaminated media that may be caused by erosion andsediment transport. The institutional controls and monitoring discussed for CMA-2 will also bepart of this alternative. The proposed containment activities include:· Removal and disposal of the contaminated media and debris from Sites 46 and 59· Regrading areas of the site to develop slopes and grades more suitable for control of runoff· Installing a vegetated soil cover· Reseeding and establishing vegetationA conceptual section of the composite cap is shown on Figure 3-3. A conceptual plan andsection of the removal area and proposed soil cover is shown on Figure 3-4. The area to becovered is about 6.8 acres and the volume to be disposed of is about 24,000 cubic yards.The Burning Ground Area sites would be cleared of existing vegetation, then large tree rootswould be grubbed out. The fill and debris would then be removed from Sites 46 and 59 withconventional earthmoving equipment. The debris would be loaded onto dump trucks andtransported to the nearest RCRA Subtitle D facility. It is assumed that 20% of the debrisremoved from Sites 46 and 59 would be considered hazardous and would be transported anddisposed of in a RCRA Subtitle C facility. The area would be prepared and a soil cover wouldbe installed at Sites 26, 27, 28, 34, and 56 according to the methods described in CMA-5.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 3-163.3.9.2 Effectiveness of CMA-9The removal of contaminated media would eliminate potential exposures and associatedecological and human health risks as well as potential future migration. Partial removal of debrisand contaminated would partially, but not completely, eliminate the need for long-termmonitoring at the Burning Ground Area. Disposal of the contaminated media in a licensedlandfill is expected to be a safe and effective means for permanent control of the material.However, the Army would retain the long-term liability for the waste, which may include somefinancial risk if the landfill leaks and causes environmental or human health risks that requireinvestigation and/or remediation.The soil cover would decrease potential exposures to contaminated media and subsequentlyreduce potential ecological and human health risks. A soil cover would also limit the potentialfor migration of contaminated media caused by erosion and sedimentation processes. Periodicsite inspections and maintenance of the vegetated cover, in conjunction with the surface waterand sediment sampling described under CMA-2, are expected to be necessary to maintain theprotectiveness of this alternative.3.3.9.3 Implementability-of CMA-9The activities proposed for CMA-9 are expected to present minimal technical and administrativedifficulties. Possible complications are expected to be associated with excavating intomixed/unknown debris, removing materials from karst features, and the potentially steep slopes.Long-term administrative oversight is required to maintain the land use restriction and overseemonitoring and maintenance of the constructed improvements. After approval by thecommissioner, coordination with the IDEM is required during the planning, construction, andreporting phases of this alternative.The construction activities associated with CMA-9 can be implemented using traditionalconstruction techniques and earth moving equipment. The required equipment, manpower, andmaterials are locally available. Special considerations will be needed to control erosion causedby storm flows and wind during construction. OSHA 29 CFR 1910.120 (Hazwopper) trainedconstruction workers will be required during activities that involve direct contact withcontaminated media, such as grading and initial placement of the soil cover.TABLE 3-1INITIAL SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONSCORRECTIVE MEASURE STUDY FOR BURNING GROUND AREAGeneral CorrectiveMeasure Technology Process Option Description ApplicabilityNo Action None None Do nothing to achieve corrective action objectives. Yes, as baseline for comparison purposes.Institutional Actions Land UseRestrictionDeed Restrictions Place restrictions on property deed to control future land use. Yes.Engineering Controls- SurfaceSurfaceEnhancementPerimeter Fence Install fencing around contaminated areas to control site access. No. Method not effective in preventing access to ecologicalreceptors.Grading/Re-vegetationRe-grade soil and re-introduce native plant species to controlerosion.Yes.Engineering Controls- ContainmentCapping Soil Cover Install 24 inches of soil over a pre-graded surface to reduce contactpotential with contaminated surface soil/sediment, enhance erosioncontrol, and reduce potential leaching to groundwater.Yes. Pending approval by IDEM.Geomembrane Cap Install impermeable geomembrane barrier over contaminatedvadose zone soils to reduce infiltration and minimize leaching ofcontaminants to groundwater.No. Would not be feasible to applicable Indiana regulations.Multi-layered Cap Install cap consisting of impermeable barrier, drainage layer, andprotective cover layer over contaminated vadose zone soils toreduce infiltration and minimize leaching of contaminants togroundwater.Yes. Pending approval by IDEM.Asphalt orConcrete CapInstall asphalt or concrete over contaminated vadose zone soils toreduce infiltration and minimize leaching of contaminants togroundwater.No. Asphalt/concrete cap typically used where final land use is aparking lot.Engineering Controls- RemovalSoil Excavation MechanicalExcavationExcavate contaminated soil in source area to remove source. Yes.Landfill Disposal Off-site RCRASubtitle D LandfillDispose of contaminated soil excavated from the source area in anexisting off-site Subtitle D (solid waste) landfill.Yes.Off-site RCRASubtitle C LandfillDispose of contaminated soil excavated from the source area in anexisting off-site Subtitle C (hazardous waste) landfill.Yes.On-site Landfill Dispose of contaminated soil excavated from the source area in anew landfill constructed on site or at the existing on-site landfill.No. New landfill is not compatible with future land usealternatives and existing landfill has been closed to furtherQ:\4599\fl010g00\inaap_cms_BG Area Draft\BGCMSTables_rev1.xls Page 1 of 2 10/13/03TABLE 3-1INITIAL SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONSCORRECTIVE MEASURE STUDY FOR BURNING GROUND AREAGeneral CorrectiveMeasure Technology Process Option Description ApplicabilityTreatment Biological NaturalAttenuationAllow naturally occurring processes (e.g. dispersion, volatilization,biodegradation, adsorption, and chemical reactions) to reducecontaminant levels.No. Natural attenuation processes not occurring at the site at ratesufficient to naturally attenuate contaminated soils to acceptablelevels.Composting Aerobically biodegrade contaminants in soils by mixing inamendments (bulking agents) and controlling environmentalNo. Metals are not treated by this method and high concentrationsof heavy metals are toxic to soil microbes.Phytoremediation Develop site to use plants to stabilize contamination. No. Contaminant concentrations and number of contaminantswould make it difficult to assess treatability.EnhancedBioremediationUse naturally occurring microorganisms (yeast, fungi, or bacteria)to degrade contaminants into less toxic or nontoxic substances.No. Existing high concentrations of metals are toxic to microbesneeded to accomplish biodegradation.Physical/ChemicalIncineration Thermally destroy contaminants in an incinerator. No. Not effective on heavy metals and high ash content of soils.Soil Washing Process contaminated soils/sediments through an attrition reactor toremove contamination from the soils.No. Percentage of soil fines is far above effective range for soilwashing.ChemicalExtractionProcess contaminated soils/sediments in an extractor with solventsor other extractant to separate contaminants from soil particles.No. High clay and fines content and high moisture renders processless effective and residuals require special handling.Solidification Physically bond or enclose soils/sediments into a stabilized mass,or induce chemical reactions to stabilize contaminants to reducetheir mobility.No. Amount of other debris at the site would yield solidificationunacceptable.Monitoring Site Monitoring Sampling andInspectionPeriodically sample soil, sediment, and/or surface water to evaluatepotential contaminant migration. Inspect the site for erosion andsigns of environmental stress.Yes.Q:\4599\fl010g00\inaap_cms_BG Area Draft\BGCMSTables_rev1.xls Page 2 of 2 10/13/03TABLE 3-2FINAL SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONSCORRECTIVE MEASURE STUDY FOR BURNING GROUND AREAGeneralCorrectiveMeasure Technology Process Option Effectiveness Implementability Relative Cost (1)Retain?No Action None None Does not address any corrective action objective. No action required. No capital.No O&M.YesInstitutionalControlsLand UseRestrictionsDeed Restrictions Limits potential human exposures through legallyrestricting future land use. Does not reduce projectedexposures to ecological receptors.Feasible given site use and planned future use. Surveyand legal assistance required. Periodic future reviewsrequired.Low capital.Low O&M.YesEngineeringControlsSurfaceEnhancementGrading andRevegetationBeneficial for erosion and runoff control, but wouldleave contaminants on the surface. Would requireadditional corrective action to be effective. Reducesprojected ecological exposures to cave resources. Alsoreduces surface area of contaminated soil and sediment,thus reducing projected foodweb ecological exposures.Routine earthwork constructibility is easy. Requiresapproval by IDEM.Low capital.Low O&M.YesCapping Soil Cover Eliminates or reduces exposure in upper 24 inches ofland. Effective for protection of human receptors.Would result in significant reduction of terrestrialecological exposure potentials to deep rooted plants anddirect exposures to fossorial animals.Routine earthwork constructibility is easy. Requiresapproval by IDEM.Medium capital.Low O&M.YesCapping Composite Clay Cap Eliminates or reduces exposure in upper 24 inches ofland. Effective for protection of human receptors.Would result in significant reduction of terrestrialecological exposure potentials to deep rooted plants anddirect exposures to fossorial animals.Routine earthwork constructibility is easy. Requiresapproval by IDEM.Medium capital.Low O&M.YesRemoval MechanicalExcavationEliminates or reduces contaminant source material.Would result in significant reduction of terrestrialecological exposure potentials.Routine earthwork constructibility is easy. Requiresapproval by IDEM.High capital.No O&M.YesDisposal Off-site RCRASubtitle D LandfillEliminates or reduces potential for future release ofcontaminants into environment through controlledcontainment.Requires off-site transport and uses landfill space. High capital.No O&M.YesDisposal Off-site RCRASubtitle C LandfillEliminates or reduces potential for future release ofcontaminants into environment through controlledcontainment.Requires long haul transport and uses landfill space. High capital.No O&M.YesMonitoring Site Monitoring Sampling andInspectionUseful to document site conditions and to evaluatepotential migration and changes in concentrations withtime. Necessary to monitor effectiveness of anyconstructed corrective action.Technical staff and laboratory are readily available. Low capital.Medium O&M.Yes(1) Relative cost represents subjective cost (high, medium, low) when comparing different process options.Q:\4599\fl010g00\inaap_cms_BG Area Draft\BGCMSTables_rev1.xls Page 1 of 1 10/13/03SECTIONFOUR Feasibility Level Cost EstimatesQ:\4599\fl010g00\inaap_cms_BG Area Final\burngrnd_cmsrev2.doc\13-Oct-03 /OMA 4-1The cost estimates in this CMS have been prepared to allow the comparison of costs among thevarious corrective measure alternatives to assist in making a site-specific risk managementdecision. The cost estimates include capital costs, annual operation and maintenance (O&M)costs, periodic costs and total present worth cost as defined below:· Capital costs are expenditures required to construct or install the corrective measure. Capitalcosts include only the expenditures that are initially incurred to implement an action,including engineering design and construction costs. Capital costs do not include the costsrequired to operate and maintain the corrective measure throughout its lifetime.· Annual O&M costs are those post-construction costs necessary to ensure or verify thecontinued effectiveness of a remedial action. They include all labor, equipment, and materialcosts associated with activities such as monitoring, site inspections, and repairs toconstructed improvements.· Periodic costs are those post-construction costs that occur periodically (but not at an annualfrequency). For this CMS, periodic costs include five year review meetings held to evaluatethe overall effectiveness of the corrective measure.· The present worth cost is the amount of money needed in the base year to cover the futurecosts associated with a particular time period at a particular interest or discount rate.Computation of the present worth cost allows for comparison of future costs discounted to abase year. For this CMS, a discount rate of 7 percent was used. The base year for theestimate is 2002.Contingency costs have been added to both the capital costs and O&M costs to help reduce therisk of possible cost overruns. Contingencies are used to cover unknowns, unforeseencircumstances, or unanticipated conditions that cannot be determined from the known data. Thetwo types of contingencies are scope contingency and bid contingency. Scope contingenciesaccount for changes and refinements to the scope of work that occur during final design as wellas changes that may occur during construction. Scope contingencies include provisions for theinherent uncertainties in characterizing waste volumes and extent. Bid contingencies coverunknown costs associated with construction or implementing the project scope. Bidcontingencies account for such items as the economic conditions at time of bidding, weatherconditions, material supply conditions, and geotechnical unknowns.Cost estimate summaries for CMA-2 through CMA-9 are provided in Tables 4-1 through 4-8.Cost worksheets for specific sub-elements of the various alternatives are provide |
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| Origin: | 2003-10-20 |
| Source: |
http://indianamemory.contentdm.oclc.org/cdm/ref/collection/p15078coll17/id/33755 |
| Collection: |
Clark County Collections |
| Rights: | http://rightsstatements.org/vocab/NoC-US/1.0/ |
| Copyright: |
Charlestown-Clark County Public Library provides access to these materials for educational and research purposes and makes no warranty with regard to their use for other purposes. The written permission of the copyright owners and/or holders of other rights such as publicity and/or privacy rights is required for distribution, reproduction, or other use of protected items beyond that allowed by fair use or other statutory exemptions. There may be content that is protected as works for hire copyright held by the party that commissioned the original work and/or under the copyright or neighboring-rights laws of other nations. Responsibility for making an independent legal assessment of an item and securing any necessary permissions ultimately rests with persons desiring to use the item. |
| Geography: |
Charlestown, Clark County, Indiana 38.4357546,-85.6577676 |
| Subjects: |
Maps Indiana Ordnance Works (U.S.) Hoosier Ordnance Plant Indiana Arsenal Indiana Army Ammunition Plant Explosives Industry--Indiana Gunpowder, Smokeless Ordnance manufacture Black powder manufacture Facility One ICI Americas Inc Clark County (Ind.) Charlestown (Ind.) United States. Army Ordnance and Ordnance Stores INAAP |
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