EPA Superfund
Record of Decision:
PB96-964418
EPA/ROD/R08-96/124
October 1996
Ellsworth Air Force Base,
Operable Unit 8, Rapid City, SD
6/7/1996
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Final
Record of Decision for
Remedial Action at Operable Unit 8
Ellsworth Air Force Base, South Dakota
United States Air Force
Air Combat Command
Ellsworth Air Force Base
June 1996
Project No.: FXBM947002
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Final Record of Decision Operable Unit 8
Ellsworth Air Force Base. South Dakota
TABLE OF CONTENTS
Chapter- - Page
1.0 DECLARATION FOR THE RECORD OF DECISION . .- 1-1
1.1 SITE NAME AND LOCATION 1-1
1.2 STATEMENT OF BASIS AND PURPOSE 1-1
1.3 ASSESSMENT OF THE SITE 1-1
1.4 DESCRIPTION OF SELECTED REMEDY 1-1
1.5 STATUTORY DETERMINATION 1-2
1.6 SIGNATURE AND AGENCY CONCURRENCE ON THE REMEDY 1-3
2.0 DECISION SUMMARY 2-1
2.1 SITE NAME AND LOCATION 2-1
2.2 OU-8 DESCRIPTION/HISTORY AND REGULATORY OVERSIGHT
ACTIVITIES 2-1
2.2.1 Description/History 2-1
2.2.2 Regulatory Oversight Activities 2-2
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-2
2.4 SCOPE AND ROLE OF RESPONSE ACTION 2-4
2.5 SITE CHARACTERISTICS 2-4
2.5.1 Soils '. 2-5
2.5.2 Sediment 2-6
2.5.3 Ground Water 2-6
2.6 SITE RISK SUMMARY 2-7
2.6.1 Human Health Risks 2-7
2.6.2 Ecological Risks 2-9
2.7 DESCRIPTION OF ALTERNATIVES 2-10
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 2-12
2.8.1 Overall Protection of Human Health and the Environment 2-13
2.8.2 Compliance with ARARs . . . 2-14
2.8.3 Long-Term Effectiveness and Permanence 2-15
2.8.4 Reduction of Toxicity, Mobility, and Volume Through Treatment 2-15
2.8.5 Short-Term Effectiveness 2-15
2.8.6 Implementabiliry 2-16
2.8.7 Cost '. 2-16
2.8.8 State Acceptance 2-17
2.8.9 Community Acceptance 2-18
2.9 SELECTED ALTERNATIVE 2-18
2.10 STATUTORY DETERMINATIONS 2-21
2.10.1 Protection of Human Health and the Environment 2-21
2.10.2 Compliance with ARARs 2-22»
2.10.3 Cost Effectiveness 2-22
2.10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies
to the Extent Possible 2-22
2.10.5 Preference for Treatment as a Principal Element 2-22
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES . 2-22
3.0 LIST OF ACRONYMS AND ABBREVIATIONS 3-1
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Final Record of Decision Operable Unit 8
Ellsworth Air Force Base, South Dakota
APPENDICES
Appendix A Figures
Appendix B Responsiveness Summary
LIST OF FIGURES
K|gure 2-1 Area Location Map
Figure 2-2 Site Location Map
Figure 2-3* OU-8 Site Area Map
Figure 2-4 EOD Area Alternative No. 3
Figure 2-5 Debris Burial Area No. 3
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Final Record of Decision Operable Unit 8
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1.0 DECLARATION FOR THE RECORD OF DECISION
1.1 SITE NAME AND LOCATION
Operable Unit 8 (OU-8), Explosive Ordnance Disposal (EOD) Area, Ellsworth Air Force
Base (EAFB), National Priority List (NPL) Site.
Meade and Pennington Counties, South Dakota
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document describes EAFB's selected remedial action for OU-8, in accordance with
the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
This decision is based on the contents of the Administrative Record for OU-8, EAFB. The US
Environmental Protection Agency (EPA) and the South Dakota Department of Environment and
Natural Resources (SDDENR) concur with the selected remedial action.
1.3 ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from OU-8, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.
1.4 DESCRIPTION OF SELECTED REMEDY
Twelve potentially contaminated areas, or operable units, have been identified at EAFB. This
ROD is for a remedial action at OU-8 and is the 11th ROD for EAFB.
OU-8 is divided into two distinct areas of investigation, Area 1 and Area 2. Area 1 is the area
surrounding the actual EOD Area itself. Area 2 consists of the Debris Burial Area where waste
from the EOD Area was buried. Alternatives for remedial action were evaluated separately for
each area.
The selected alternative for Area 1 (EOD Area), vegetative soil cover and institutional controls,
includes the following major components:
Constructing an earth cover over a portion of the EOD Area;
Institutional controls for the EOD Area;
Long-term sediment sampling; and,
Long-term maintenance of earth cover.
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Final Record of Decision Operable Unit 8
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The selected alternative for Area 2 (Debris Burial Area), vegetative soil cover and institutional
controls, includes the following major components:
Constructing an earth cover over the Debris Burial Area;
Institutional controls for the Debris Burial Area; and, long-term maintenance of earth
cover.
1.5 STATUTORY DETERMINATION
The selected remedies are protective of human health and the environment, comply with
Federal and State of South Dakota requirements that are legally applicable or relevant and
appropriate to the remedial action, and are cost-effective. These remedies use permanent
solutions and alternative treatment (or resource recovery) technologies, to the maximum extent
practicable for OU-8. However, because treatment of the principal threats of the OU was not
practical, this remedy does not satisfy the statutory preference for treatment as a principal
element. Because of the low risk of contaminants onsite, under current and future risk
scenarios, removal or treatment of the contaminants at OU-8 is not required. However,
because of the proximity of OU-8 to the Base boundary and the potential for contaminants
(particularly dioxins) to be transported into adjacent drainages and potentially off Base where
they may accumulate and pose future risk, containment of onsite surface soil is justified.
Containment of surface soil and exposed debris by constructing an earth cover will also satisfy
State concerns regarding final covers over inactive waste disposal areas and reduce the
potential for potentially unidentified contaminants from leaching into the ground water.
Because this remedy will result in low levels of hazardous or potentially hazardous substances
remaining onsite beneath the earth covers, a review will be conducted no less than every five
years after signing of the ROD to ensure that the remedy continues to provided adequate
protection of human health and the environment. If the results of the review indicate that
conditions at OU-8 have changed, the remedies may be modified to reflect these changes.
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1.6 SIGNATURE AND AGENCY CONCURRENCE ON THE REMEDY
BRETT M.DULA Date
Lieutenant General, USAF
Vice Commander
JACK W. MCGRAW Date
Acting Regional Administrator
U.S. Environmental Protection Agency Region 8
NETTIE H. MYERS, Secretary Date
Department of Environment and Natural Resources
State of South Dakota
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Final Record of Decision Operable Unit 8
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1.6 SIGNATURE AND AGENCY CONCURRENCE ON THE REMEDY
BRETT M. DULA Date
Lieutenant General, USAF
Vice Commander
W. MCGRAW Date
Aping Regional Administrator
f.S. Environmental Protection Agency Region 8
NETTIE H. MYERS, Secretary Date
Department of Environment and Natural Resources
State of South Dakota
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Final Record of Decision Operable Unit 8
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1.6 SIGNATURE AND AGENCY CONCURRENCE ON THE REMEDY
BRETT M. DULA
Lieutenant General, USAF
Vice Commander
Date
V
JACK W. MCGRAW
Acting Regional Administrator
U.S. Environmental Protection Agency Region 8
Date
'car*
NETTIE H. MYERS,
Department of Enviro:
State of South Dakota
Sec
Date
Natural Resources
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May 7, 1996
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Final Record of Decision Operable Unit 8
Ellsworth Air Force Base, South Dakota
2.0 DECISION SUMMARY
2.1 SITE NAME AND LOCATION
EAFB is a U.S. Air Force (USAF) Air Combat Command (ACC) installation located 12 miles
east of Rapid City, South Dakota, and adjacent to the small community of Box Elder (Figure
2-1).
EAFB covers approximately 4,858 acres within Meade and Pennington counties and includes
runways and airfield operations, industrial areas, and housing and recreational facilities
(Figure 2-2). Open land, containing a few private residences, lies adjacent to EAFB on the
north, south, and west, while residential and commercial areas lie to the east of the Base.
2.2 OU-8 DESCRIPTION/HISTORY AND REGULATORY OVERSIGHT ACTIVITIES
2.2.1 Description/History
EAFB was officially activated in July 1942 as the Rapid City Army Air Base, a training
facility for B-17 bomber crews. It became a permanent facility in 1948 with the 28th Strategic
Reconnaissance Wing as its host unit. Historically, EAFB has been the headquarters of
operations for a variety of aircraft, as well as the Titan I Intercontinental Ballistic Missile, and
the Minuteman I and Minuteman II missile systems. The Air Force has provided support,
training, maintenance, and/or testing facilities. Presently, the 28th Bombardment Wing (B-1B
bombers) is the host unit of EAFB.
Operable Unit 8 (OU-8) is the current designation for the area surrounding and including the
explosive ordnance disposal (EOD) Area. As stated above, OU-8 is divided into two distinct
areas of investigation. Area 1 is the actual EOD Area itself. Area 2 consists of the Debris
Burial Area where waste from the EOD Area was buried. Sediments in drainages within and
adjacent to the EOD Area are also included in OU-8. OU-8 is located in the extreme northeast
corner of EAFB. Figure 2-2 shows the location of OU-8 at EAFB.
The EOD Area is approximately 600 ft by 1,350 ft and is located in sloped rugged terrain in
the northeastern corner of EAFB. Service roads parallel the two north-south trending ridges
located along the eastern and western edges of this site. The area within the confines of these
service roads is where explosive ordnance demolition was formerly conducted. Along with
ordnance disposal activities, it is reported that a herbicide spill occurred in May 1982. Terrain
in this area slopes predominantly toward the north. An unnamed ephemeral drainageway
exists along the east and west edges and in the central portion of this area. This drainageway
conducts surface flow off the site in a northerly direction (Figure 2-3).
The Debris Burial Area is approximately 300 ft by 150 ft and is located on a ridge south of the
EOD Area, in a less rugged area. Spent metal casings (small arms) are visible at the surface
in this area. The terrain surrounding the ordnance burial area slopes gently toward the east
(Figure 2-3).
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The habitat on OU-8 is dominated by mixed grass prairie. OU-8 is not developed; that is, there
are no buildings, parking areas, or even paved roads within the OU. Human activities, such as the
detonation of active explosives, and the burial of debris created by explosives detonation, have
visibly altered only a small portion of the OU-8 habitat. The most disturbed area on OU-8 is the
EOD Area, which collectively refers to a burn pit area, burn furnace area, and a detonation area.
The majority of the EOD Area is characterized by native black surface soil and very little
vegetation.
The predominant soil types at OU-8 are clays. However, in the EOD Area, shale is present very
near the surface and in some cases is exposed at the surface. Movement of ground water through
these formations is slow.
The shallow aquifer (10 - 15 ft below ground level) that lies beneath the majority of EAFB is
considered a potential drinking water source and possibly discharges to the surface. However,
unlike other areas of the Base, at OU-8 there are not significant deposits of sands and gravels.
Consequently, very little ground water can be pumped from wells in the shallow aquifer. Total
dissolved solids (TDS) concentrations are above the State of South Dakota standard of 10,000
milligrams per liter (mg/L) in some monitoring wells (ARSD Chapter 74:03:15, Groundwater
Quality Standards). Therefore, the shallow aquifer at OU-8 is not considered a potential source of
drinking water for humans. At other locations on-Base, the shallow ground water is considered a
potential drinking-water source.
Deeper bedrock aquifers also exist beneath EAFB. These deeper aquifers are separated from the
shallow aquifer by 800 feet of impermeable clays and silts. In the past, EAFB used these deeper
aquifers for its water supply. Presently, EAFB obtains its potable water from the Rapid City
Municipal Distribution System.
2.2.2 Regulatory Oversight Activities
Environmental investigation activities at EAFB were initiated by the Air Force in 1985 through an
Installation Restoration Program (IRP) Phase I Installation Assessment/Records Search and Phase
II, Confirmation/Quantification. The Phase I study, dated September 1985, identified a total of
17 locations at EAFB where releases involving hazardous substances potentially occurred.
In Phase II of the ERJP investigation, field activities included soil vapor surveys, geophysical
surveys, surface and subsurface soil sampling, ground-water sampling, ground-water hydrologic
testing, and ecological investigations.
On August 30, 1990 (55 Federal Register 35509), EAFB was listed on the EPAs NPL. A
Federal Facility Agreement (FFA) was signed in January 1992 by the Air Force, EPA, and the
State of South Dakota (State) and went into effect on April 1, 1992. The FFA establishes a
procedural framework and schedule for developing, implementing, and monitoring appropriate
response actions for EAFB in accordance with CERCLA, as amended by SARA, and the NCP. It
also states the oversight procedures for EPA and the State to ensure Air Force compliance with
the specific requirements. The FFA identified 11 potential source-area
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operable units as well as a Base-wide ground-water operable unit. The Base-wide ground-
water OU is primarily used "to address contaminated ground water that was not addressed
during an investigation of a site-specific OU.
Listing on the NPL and execution of the FFA required the U.S. Air Force to perform a
remedial investigation/feasibility study (RI/FS) to investigate the 12 operable units. In 1993
and 1994, an extensive RI field program was conducted to characterize conditions at OU-8.
The program included drilling and sampling of boreholes, installation of monitoring wells,
ground-water sampling, geotechnical analysis of soil samples, ecological evaluation,
assessment of human health risks, and review and compilation of previous IRP investigations.
Collection and laboratory analysis of soil, ground-water, surface-water, and sediment samples
were included in the RI field program.
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
Community relations activities that have taken place at EAFB to date include:
FFA process. After preparation of the FFA by the USAF, EPA, and SDDENR, the
document was published for comment. The FFA became effective April 1, 1992.
Administrative Record. An Administrative Record for information was established
in Building 8203 at EAFB. The Administrative Record contains information used to
support USAF decision-making. All the documents in the Administrative Record are
available to the public.
Information repositories. An Administrative Record outline is located at the Rapid
City Library (public repository).
Community Relations Plan (CRP). The CRP was prepared and has been accepted
by EPA and the State of South Dakota and is currently being carried out. An update
to this plan will be prepared in 1996.
Restoration Advisory Board (RAB). The RAB has been formed to facilitate public
input in the cleanup and meets quarterly. In addition to USAF, EPA, and State
oversight personnel, the RAB includes community leaders and local representatives
from the surrounding area.
Mailing list. A mailing list of all interested parties in the community is maintained
by EAFB and updated regularly.
Fact sheet. A fact sheet describing the status of the IRP at EAFB was distributed to
the mailing list addressees in 1992.
Open house. An informational meeting on the status of the IRP and other
environmental efforts at EAFB was held on May 6, 1993. An open house was held
November 16, 1995 in conjunction with the Restoration Advisory Board meeting.
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Information on the status of environmental efforts at EAFB was provided at the open
house.
Newspaper articles. Articles have been written for the Base newspaper regarding
IRP activity.
Proposed Plan. The proposed plan on this action was distributed to the mailing list
addressees for their comments.
A public comment period was held from December 28, 1995 to January 27, 1996, and a public
meeting was held on January 11, 1996. At this meeting, representatives from EAFB answered
questions about the remedial action. A response to the comments received during this period
is included in the Responsiveness Summary, which is part of this ROD.
This ROD is based on the contents of the Administrative Record for OU-8, in accordance with
CERCLA, as amended by SARA, and the NCP. The RI/FS reports and the Proposed Plan for
OU-8 provide information about OU-8 and the selected remedy. These documents are
available at the Information Repositories at EAFB and the Rapid City Public Library.
2.4 SCOPE AND ROLE OF RESPONSE ACTION
The FFA identified 1 1 potential source area operable units (OUs) as well as a Base-wide
ground-water operable unit. The 12 operable units are identified as follows:
OU-1 Fire Protection Training Area
OU-2 Landfill Nos. 1 and 6
OU-3 Landfill No. 2
OU-4 Landfill No. 3
OU-5 Landfill No. 4
OU-6 Landfill No. 5
OU-7 Weapons Storage Area
OU-8 Explosive Ordnance Disposal Area
OU-9 Old Auto Hobby Shop Area
OU- 1 0 North Hangar Complex
OU-11 Base-wide Ground Water
OU-1 2 Hardfill No. 1
This ROD is to document the selected remedy for the preferred remedial action (RA) at OU-8
and is the llth ROD for EAFB. The remedial action objectives (RAOs) are to reduce the
potential risks posed by contaminants in surface soils id to reduce the mobility of potential
contaminants in the landfill through containment.
2.5 SITE CHARACTERISTICS
This section describes the presence and distribution of contaminants at OU-8 as a result of past
activities.
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2.5.1 Soils
Volatile Organic Compounds (VOCs)
Toluene was reported in six surface and seven subsurface soil samples from the EOD Area, at
a maximum concentration of 18 micrograms per kilogram (/^g/kg). The source of the toluene
in this area is not known. Toluene was not reported in either the capillary fringe samples in
the EOD Area or in the surface and subsurface samples from the Debris Burial Area.
Semivolatile Organic Compounds (SVOCs)
Several SVOCs were detected in soil samples collected at OU-8. The occurrence of bis (2-
ethylhexyl) phthalate in samples collected at the south end of the EOD Area in an IRP
Phase II, Stage 1 soil sample was confirmed in the 1993 RI. The occurrence of bis (2-
ethylhexyl) phthalate in subsurface soil collected downgradient of the EOD Area was also
confirmed by the 1993 RI. Other reported SVOCs include polycyclic aromatic hydrocarbons
(PAH) which, with the exception of chrysene, were reported in one sample only. Chrysene
was reported in five surface samples at a maximum concentration of 390 Mg/kg and five
subsurface samples, at a maximum concentration 450 Mg/kg, respectively. Chrysene was not
reported in the surface and subsurface samples from the EOD Area.
Total Petroleum Hydrocarbons (TPH)
Total petroleum hydrocarbons as jet fuel were reported in a total of eight surface soil samples
at a maximum value of 310 millgrams per kilogram (mg/kg), and in four subsurface soil
samples at a maximum reported value of 190 mg/kg. Jet fuel was reported once at 200 mg/kg
in a surface soil sample from the EOD Area, but was not reported in the subsurface samples
from the same area. Jet fuel was reported in five surface soil samples and four subsurface
samples in the debris burial area.
Pesticides
A total of seventeen different pesticides (not including prometon) were reported in the eighty-
five soil samples collected at OU-8. No pesticides were reported in the samples collected from
the debris burial area. One soil sample taken immediately above the water table (capillary
fringe) had reported methoxychlor at 5.6 Mg/kg. The majority of the reported pesticide values
were from samples collected at the surface (0-0.5 ft) and the near surface (1.0-1.5 ft). The
most frequently reported compound was endrin aldehyde, which was reported in eight surface
samples and six subsurface samples. The highest reported pesticide concentration was endrin
at a concentration of 4.8
Prometon is the active ingredient in Pramitol and was reported in 1 1 surface soil samples at a
maximum concentration of 620 Mg/kg and two subsurface soil samples at a maximum
concentration of 430 Mg/kg. Prometon distribution is isolated in two distinct areas. One area
is located in the southern portion of the EOD Area, and is approximately 300 x 300 ft. The
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other area is approximately 400 x 400 ft, and is located north of the EOD Area. Prometon
was nor sported in the capilla-y fringe soi imples. and was re{ 'ited in only one subsurface
soil san.ple. The reported pesucides are cc idered to be a resuii of pest management
practices on the Base.
Inorganic Contaminants
A comparison of the OU-8 results and the background results shows that 30 inorganic analytes
were reported at least once above background concentrations. The most frequently reported
aftalytes above background values were nickel (69%), manganese (63%), lead (62%) and
copper (61 %). Because the above analytes and the other anions (negatively charged ions) and
inorganic constituents were reported at higher or similar values in the subsurface samples as
compared with the surface samples, the results indicate that reported inorganic analytes and
anions are a result of geologic variations and not a result of past activities at the EOD Area.
Dioxin/Furan
The surface soil samples and five of the subsurface soil samples were analyzed for
dioxin/furan. The reported dioxin/furan included 2,3,7,8 tetrachlorodibenzo-p-dioxin;
1,2,3,7,8 pentachlorodibenzo-p-dioxin; 1,2,3,4,7,8 hexachlorodibenzo-p-dioxin; 1,2,3,6,7,8
hexachlorodibenzo-p-dioxin; 1,2,3,7,8,9 hexachlorodibenzo-p-dioxin; 1,2,3,4,6,7,8
heptachlorodibenzo-p-dioxin and octachlorodibenzo-p-dioxin. The international toxic
equivalents corresponding to the concentrations of dioxins in the soil at OU-8 were below the
1,000 picogram per gram (pg/g) level of concern for residential soil.
2.5.2 Sediment
Two sediment samples were collected in June 1993 as part of the 1993 RI. Both samples were
collected from Area 1. Samples were analyzed for Target Compound List (TCL) VOCs,
SVOCs, pesticides/polychlorinated biphenyls (PCBs); Target Analyte List (TAL) analytes; ~
TPH [jet propulsion fuel No. 4 (JP-4)]; prometon; and explosives. VOCs, pesticides/PCBs,
TPH (JP-4), and explosives were not reported in the OU-8 sediment samples. Prometon was
reported at concentrations of 150 Mg/kg and 110 Mg/kg. There are no State or Federally
promulgated cleanup levels established for sediment.
2.5.3 Ground Water
Ground-water samples collected during the 1993 RI at OU-8 and were analyzed for TCL
VOCs, SVOCs, Pesticides/PCBs, TAL analytes, TPH (JP-4), prometon, and explosives. In
addition, one monitoring well was analyzed for anions, and dioxins/furanf Pesticides/PCB,
promeion, TPH O-P-4), explosives, and dioxins/furans were not reported hi the OU-8
ground-water samples.
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Volatile Organic Compounds (VOCs)
One VOC (carbon disulfide) and one tentatively identified compound (TIC, carbon dioxide)
were reported at OU-8. The carbon disulfide was reponed at one location at a concentration
ofCU^g/L.
Semivolatile Organic Compounds (SVOCs)
Three separate SVOCs were reported in OU-8 ground-water samples. Di-n-butyl phthalate,
4-Chloroaniline, and bis(2-ethylhexyl)phthalate were each reponed once at concentrations of
, 1 Mg/L, and 2 /zg/L respectively.
2.6 SITE RISK SUMMARY
2.6.1 Human Health Risks
Risk Assessment Process
The assessment of human health risks for this OU considered the following topics:
(1) Chemicals of concern (COCs) in ground-water, sediment, and soil samples taken at
OU-8;
(2) Current and future land-use conditions;
(3) Potential environmental pathways by which populations might be exposed;
(4) Estimated exposure point concentrations of COCs;
(5) Estimated intake levels of the COCs;
(6) Toxicity of the COCs; and
(7) Uncenainties in the assessments of exposure, toxicity, and general risks.
Noncarcinogenic and carcinogenic risks were calculated for the following three potential
exposure groups at OU-8:
( 1 ) Current EAFB maintenance personnel engaged in maintenance and ordnance disposal
activities at Area 1 ;
(2) The future child/adult living in either Area 1 or Area 2 who is exposed to surface soil
and shallow ground water;
(3) Future adult construction workers who excavate at either Area 1 or Area 2 for
building residences.
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A qir~4native risk assessment was performed for the ground water, surface water, soil,
sec* and air. The risk assessment evaluated potential effec? * on human health posed by
ex; ~ to contaminants within OU-8. Carcinogenic risks were estimated as the incremental
pro^oility of an individual developing cancer over a lifetime as a result of exposure to a
potential cancer- causing chemical. The acceptable risk range expressed as a probability is one
cancer incident in one-hundred thousand people to one cancer incident in one million people.
This level of risk is also denoted by 1 x 10"* to 1 x 10"6. Risks within the acceptable risk range
may or may not warrant remedial action depending upon site-specific circumstances. Risks
below this range cannot be differentiated from the background occurrence of cancer in human
populations. Risks calculated in a risk assessment are potential risks and are excess (i.e., over
background) cancer risks due to exposure from contaminants at the OU.
Noncarcinogenic health risks are evaluated using a hazard index. If the hazard index is less
than or equal to one, the contaminant concentration is considered an acceptable level and
generally assumes that the human population may be exposed to it during a 30-year period
without adverse health effects.
Risk Assessment Results
The risk assessment for OU-8 indicated that there are no unacceptable noncarcinogenic or
carcinogenic risks at the OU under current land use conditions, resulting from activities
conducted at OU-8. There were no carcinogenic risks identified in the OU-8 risk assessment
as having a risk greater than 1 x 10"4, resulting from activities conducted at OU-8. Dioxins in
surface soil were the only chemicals identified in the RI present at concentrations greater than
10"6. Risk associated with the dioxins in the surface soil is in the 10~5 range. Noncarcinogenic
and carcinogenic risks were also identified for the OU from naturally-occurring inorganic
chemicals in the soil and ground water; however, risks from naturally-occurring chemicals are
not considered for remediation.
Chemicals detected in the ground water that contributed to excess risk are considered to be
naturally occurring. Therefore, remedial action is not warranted for the ground water at this
time. The ground water at OU-8 will be included as pan of the Base-wide ground water
evaluation for OU-11.
Risk Summary
Remedial action is warranted for OU-8 because of its proximity (particularly Area 1) to the
Base boundary and the potential for contaminants (primarily dioxins) to be transported into
adjacent drainages and potentially off Base. Health risks from human contact to the
contaminants wou. * unacceptable if the contaminants accumulate to high concentrations in
th irainage areas. Area 2, action is warranted because of the presence of buried and
exposed surface de; from the EOD area and the potential for future exposure to unidentified
contaminants in the ourial pits. Future residents in the area may come in contact or incidently
ingest the contaminants. There are also low concentrations of dioxins in the surface soil in
this area. Action is warranted to prevent human contact with surface debris, prevent
potentially unident;ried contaminants from leaching into underlying ground water, prevent
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contaminants from accumulating in the drainage channels and to establish a final cover over
the waste disposal area as required by the State of South Dakota.
Because the EOD Area and Debris Burial Area at OU-8 are former waste disposal areas, the
Air Force used guidance developed by EPA titled Presumptive Remedy for CERCLA Municipal
Landfill Sites (OSWER Directive 9355.0-49FS). The presumptive remedy for landfills is
onsite containment of landfill contents. Although the two areas at OU-8 are not technically
landfills, they exhibit characteristics (e.g., buried waste, waste disposal) that allow application
of the same types of remedial technologies as those applied to landfills. Using the presumptive
remedy strategy, a quantitative risk assessment is not necessary to evaluate whether the
containment remedy addresses all exposure pathways and contaminants potentially associated
with a disposal area. Rather, all potential exposure pathways can be identified using the
conceptual site model and compared with the pathways addressed by the presumptive remedy.
Containment of the disposal area contents addresses exposure pathways and risks normally
associated with these areas. The contaminant exposure pathways for the potential risks at
OU-8 include (1) direct physical human contact with the disposal area contents, (2)
consumption or contact with surface soil that is or may become contaminated, (3) consumption
or contact with potentially contaminated surface water, and (4) ingestion of potentially
contaminated sediment in the drainages adjacent to and downgradient of OU-8.
Actual or threatened releases of hazardous substances from OU-8, if not addressed by
implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, and the environment.
2.6.2 Ecological Risks
An ecological risk evaluation of OU-8 was based on a combination of data and literature
reviews, field and laboratory analyses, analyte evaluation and screening, and preliminary risk
screening. The pertinent findings are summarized below.
A variety of animal species may live, forage, or nest in OU-8 habitats, particularly in the
drainage channels. These species include various types of invertebrates, amphibians, birds,
and mammals. Because of the altered natural environment at OU-8, rare, threatened, or
endangered species are unlikely to utilize the area for more than brief, periodic habitat. Due
to the low levels of contaminant concentrations, the contaminants do not pose an unacceptable
risk to these species. In addition, the limited contact these species would have with the OU-8
area ensures unacceptable risk to a single individual will not occur. Chapter 6 of the OU-8 RI
gives a detailed evaluation of ecological risk assessment and potential ecological receptors.
Terrestrial vegetation and soil faunal communities do not reveal characteristics that indicate
chemical-related impacts. This finding is consistent with the relatively low levels of
contaminants in the soil.
Findings of the RI indicate that the contaminants at OU-8 are not altering the ecology to
noticeable levels. A Basewide ecological risk assessment will be conducted as part of OU-11,
and OU-8 will be included in this Basewide evaluation.
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2.7 DESCRIPTION OF ALTERNATIVES
Presumptive Remedy for CERCLA Municipal La; ' Sites, (OSWER Directive 9355.3-1 IPS)
was the basis for the focused feasibility study (Fi... The OSWER directive established
containment of the contamination within landfills and the collection and treatment of landfill
gas within the landfill boundary (if applicable) as the presumptive remedy for CERCLA
municipal landfills. Although not specifically identified as municipal landfills, The EOD Area
and Debris Burial Area at OU-8 exhibit characteristics that make this presumptive remedy
applicable. Chemicals were detected in the EOD Area that are not highly mobile in the soil
profile but may be transported via paniculate matter. The Debris Burial Area is similar to a
landfill although it received waste from only one source (the EOD Area). Containment of
soils from these two areas is the most feasible and cost-effective alternative for this OU. Also,
since the focus of the remedial action is primarily directed at potential future risks from
migrating contaminants and not from present risks associated with the site, containment is the
practical alternative. Therefore, components of EPA's presumptive remedy can be
incorporated to facilitate alternative development and selection. These areas at OU-8 do not
have the characteristics to produce significant quantities of leachate or gases. Ground water is
not a pathway of concern at OU-8.
OU-8 has two distinct areas of concern. Area 1 (EOD Area) lies in rugged sloped terrain near
the north edge of the OU and Area 2 (Debris Burial Area) lies above the EOD Area on a
relatively flat ridge. Separate alternatives are presented for each of these areas.
The primary concern at Area 1 is the potential for dioxins in the surface soil to migrate into
adjacent drainages and off Base via suspended paniculate matter in storm water runoff. As a
result, contaminants would accumulate in the drainage channels at higher concentrations than
currently detected. Although the risks associated with dioxins are within the acceptable range,
soils containing dioxins should be prevented from migrating off Base and potentially
accumulating downgradient. Dioxins were reported in lesser quantities in Area 2 and the
potential for migration of dioxins from this area is lower since the area is relatively flat and
less susceptible to erosion. The primary concern in Area 2 is the presence of buried waste
from the EOD Area. There is also some debris exposed on the surface, primarily spent small
caliber shell casings. A final cover is required over Area 2 to also comply with State
requirements.
EOD AREA ALTERNATIVES
Alternative 1: No Action
The no action alternative represents the baseline condition at OU-8 and refers to
taking no further action at OU-8.
The no action alternative does not meet remedial action objectives for OU-8.
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Alternative 2: Institutional Controls
This alternative includes restrictions on land use and site access restrictions. Major components
of this alternative are:
Restrict access to the area by installing a fence around the EOD Area.
Install "Restricted Access" signing every 100 feet along the fence and provide pad
locks on gates that provide access to the site.
Annotate base records to limit the future use of the area to non-intrusive activities,
or activities that will not impact the integrity of the cover.
Conduct sediment sampling to determine the extent of potential migration of
chemicals in the surface soil into adjacent drainages.
Alternative 2 does not meet the remedial action objectives for OU-8.
Alternative No. 3: Vegetative Soil Cover/Institutional Controls
This alternative includes physical modification of the site to reduce erosion and potential future
risk from chemicals that could migrate and accumulate offsite. The selected alternative for Area 1
(EOD Area), vegetative soil cover and institutional controls, includes the following major
components:
Constructing an earth cover over the EOD Area;
Institutional controls for the EOD Area;
Long-term sediment sampling; and,
Long-term maintenance of earth cover.
Alternative 3 meets the remedial action objectives for OU-8.
DEBRIS BURIAL AREA ALTERNATIVES
Alternative No. 1: No Action
. The no action alternative represents the baseline condition at OU-8 and refers to
taking no further action at OU-8.
Alternative No. 2: Institutional Controls
This alternative includes restrictions on land use and site access restrictions. Major components
of this alternative are:
Restrict access to the area by installing a fence around the Debris Burial Area.
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Install "Restricted Access" signing every 100 feet along the fence and provide pad
locks on gates that provide access to the site.
Annotate base records relating to fiiture use of area to preclude it from being used
for residential purposes.
Alternative 2 does not meet the remedial action objectives for OU-8.
Alternative No. 3: Vegetative Soil Cover/Institutional Controls
This alternative includes physical modification of the site to reduce erosion and potential risk.
The selected alternative for Area 2 (Debris Burial Area), vegetative soil cover and institutional
controls, includes the following major components:
Constructing an earth cover over the Debris Burial Area;
Institutional controls for the Debris Burial Area; and, long-term maintenance of
earth cover.
Alternative 3 meets the remedial action objectives for OU-8.
2.8 SUMiMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The analysis of alternatives coupled with the use of the presumptive remedy results in a narrower
range of feasible approaches to addressed remedial activities at OU-8.
The RAOs for OU-8 are as follows:
Area 1 - EOD Area
Prevent contaminated surface soil from migrating offsite.
Provide protection against direct contact or ingestion of surface soils containing
contaminants.
Area 2 - Debris Burial Area
Contain buried and exposed debris and prevent contaminated surface soil from
migrating offsite.
Provide protection against direct contact or ingestion of soils containing
contaminants.
The areas of attainment have been identified as the area encompassing the EOD Area (Area 1)
and the extent of the Debris Burial Study Area (Area 2). Area 1 is approximately 15.5 acres in
size; however, the primary area of cover placement is approximately the 4.5 acres surrounding the
burn pit, burn furnace, and detonation site shown on Figure 2-4. Study
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Area 2 is approximately 8 acres in size; however, cover placement is limited to the 1.5 acres
surrounding the actual debris burial pits (Figure 2-5).
Pursuant to Section 300.430(e)(9)(iii) of the EPA's revised National Contingency Plan, the
remedial action to be implemented should be selected based upon consideration of nine
evaluation criteria. These criteria are as follows:
1. Overall protection of human health and environment.
2. Compliance with applicable or relevant and appropriate requirements (ARARs).
3. Long-term effectiveness and permanence.
4. Reduction of toxicity, mobility, or volume of contamination.
5. Short-term effectiveness.
6. Implementability.
7. Cost.
8. State acceptance.
9. Community acceptance.
The following sections provide a brief review and comparison of the remedial alternatives
according to the EPA's evaluation criteria.
2.8.1 Overall Protection of Human Health and the Environment
The assessment of this criterion considers how the alternatives achieve and maintain protection
of human health and the environment.
EOD Area
Alternative 1 (No Action) does not provide protection against contact with chemicals in the
surface soil and does not reduce the potential for migration of chemicals via storm water
runoff. Alternative 2 (Institutional Controls) provides protection from direct contact with
surface soils by reducing exposure potential through site access restrictions and land and
ground-water use restrictions but does not provide protection against erosion of surface soil.
Alternative 3 does not provide treatment but does provide containment (cover) of the surface
soil at the EOD Area, reducing potential exposures and preventing migration.
Debris Burial Area
Alternative 1 (No Action) does not provide protection against contact with chemicals and
debris in the surface soil. Alternative 2 (Institutional Controls) provides protection from direct
contact with contents in Debris Burial Area by reducing exposure potential through site access
restrictions and land and ground-water use restrictions. Under Alternative 3, placement of a
vegetative cover would reduce risk by reducing potential exposures in this area and would also
prevent migration of surface soil.
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2.8.2 Compliance with ARARs
Alternatives are assessed under this criterion in terms of compliance with ARARs. Applicable
requirements include cleanup standards, standards of control and other substantive
environmental protection requirements, and criteria or limitations promulgated under Federal
or State laws. The laws specifically address a hazardous substance, pollutant, contaminant,
remedial action, location or other circumstances at a CERCLA site.
Relevant and appropriate requirements address problems or situations sufficiently similar to
those encountered at a CERCLA site that their use is well suited to the environmental and
technical factors at a particular site. ARARs are grouped into these three categories:
Chemical-Specific ARARs are health or risk-based numerical values or
methodologies which, when applied to site-specific conditions, result in
establishment of the amount or concentration that may be found in, or
discharged to, the environment.
Location-Specific ARARs restrict the concentration of hazardous substances or
the conduct of activities solely because they are in specific locations such as
flood plains, wetlands, historic places, and sensitive ecosystems or habitats.
Action-Specific ARARs are usually technology or activity-based requirements
or limitations on actions taken with respect to hazardous wastes.
A summary evaluation of Federal and State ARARs pertinent to this remedial action is
provided in Table 2-1 at the end of Section 2.0 and a narrative discussion of compliance with
ARARs is provided below for the alternatives considered.
State of South Dakota guidelines for petroleum in soils are the only known chemical-specific
ARARs for soil at OU-8. Both areas contain low concentrations of TPH in the soil. TPH
concentrations are below levels that would warrant action under State petroleum release
guidelines and in compliance with State ARARs. Ground water at OU-8 is not contaminated
above maximum contaminants levels (MCLs).
There are no known location-specific ARARs for either area of OU-8.
There are no action-specific ARARs for Area 1. Since Area 2, the Debris Burial Area, is a
disposal area and contains buried waste and debris, the State of South Dakota is requiring that
a final cover be placed over the area. There are no unacceptable current risks associated with
the Debris Burial Area; therefore, the State of South Dakota has agreed that Alternative 3
(covering) would be acceptable in meeting the substantiative requirements for closure of this
area (ARSD 74:27:15:02 to 74:27:15:11,.inclusive). There are no other action-specific
ARARs for OU-8.
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2.8.3 Long-Term Effectiveness and Permanence
The assessment of this criterion considered the long-term effectiveness of alternatives in
maintaining protection of human health and the environment after response action objectives
have been met.
Alternative 1 would not provide additional effectiveness or permanence in reducing the
potential for direct contact or ingestion of surface soil. No further controls for the OU would
be developed under this alternative.
Alternative 2 would provide increased effectiveness through site access restrictions (in addition
to the inherent Base access restrictions) and land and ground-water use restrictions for both
areas.
Alternative 3 would offer the highest level of long-term effectiveness. Protection would be
accorded by the native soil cover at both areas. Erosion would be limited by the development
and maintenance of a vegetated area. Upon completion of the covers, long-term maintenance
would be required. At Area 1, sediment monitoring would be used to determine the
effectiveness of the cover and vegetation in reducing erosion and migration of chemicals in
storm water runoff.
2.8.4 Reduction of Toxicity, Mobility, and Volume Through Treatment
The assessment of this criterion involves considering the anticipated performance of specific
treatment technologies an alternative may employ.
Alternatives 1 and 2 would not provide for the reduction of toxicity, mobility, or volume of
the chemicals of concern. Alternative 3 does not use treatment technologies to reduce toxicity
or volume, but reduces the mobility of the chemicals of concern in both areas through
containment.
2.8.5 Short-Term Effectiveness
The assessment of this criterion considers the effectiveness of alternatives in maintaining
protection of human health and the environment during the construction of a remedy until
response action objectives have been met.
Alternatives 2 and 3 may create a short-term increase in risk (from dust inhalation) during
remedial activities. Disturbance of surface soil during earthwork could result in exposure to
workers. Dust mitigation during these activities would minimize this potential impact.
Implementation of Alternative 3 would increase the potential for erosion of disturbed soils
during construction, although erosion control measures would help to minimize this effect.
Because of the low level of risk, it is not anticipated that the proposed alternatives would
significantly impact community health and safety during the implementation period.
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2.8.6 Implementability
The assessment of this L: 'lerion considers the administrative and technical feasibility of
implementing the alternatives and the availability of necessary goods and services for
implementation of the response action.
There is nothing to implement under Alternative 1 because of the no action scenario.
Alternative 2 requires no special or unique activities and could be implemented using locally
available materials and contractors. Alternative 3, installing an earth cover, could be
implemented with standard construction equipment, materials, and methods.
2.8.7 Cost
The assessment of this criterion considers the capital and operation and maintenance (O&M)
costs associated with each alternative. Alternatives are evaluated for cost in terms of both
capital costs and long-term O&M costs necessary to ensure continued effectiveness of the
alternatives. Capital costs include the sum of the direct capital costs (materials and labor) and
indirect capital costs (engineering, licenses, permits). Long-term O&M costs include labor,
materials, energy, equipment replacement, disposal, and sampling necessary to ensure the
future effectiveness of the alternative. The objective of the cost analysis is to eliminate those
alternatives that do not provide measurably greater protection of human health and the
environment for additional costs that may be incurred. Costs presented in the ROD are
estimated projected costs and do not include yearly escalation adjustments. Final costs will be
developed during the Remedial Design and will be structured using the Remedial Action Work
Breakdown structure as required by ER 1110-3-1301.
A summary of the costs for each alternative is as follows:
Alternative No. 1 (No Action) - EOD and Debris Burial Areas
Total Capital Costs
Annual (Sampling/Analysis) Costs: SO
Total 30-Year Present Value for Annual Costs
Years = 30
Discount Rate = 5%
TOTAL 30-Year Present Value
$0
SO
$0
Alternative No. 2 - (Institutional Controls) - EOD Area
Total .'ital Costs
Annu«., (Sampling/ Analysis/O&M) Costs - Years 1-5 only: 529,000
Total 30-Year Present Value for Annual Costs
Years = 30
Discount Rate = 5%
535,000
$126,000
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Alternative No. 2 - (Institutional Controls) - EOD Area
TOTAL 30-Year Present Value
$161,000
Alternative No. 2 - (Institutional Controls) - Debris Burial Area
Total Capital Costs
Annual (Sampling/ Analysis/O&M) Costs: $0
Total 30-Year Present Value Tor Annual Costs
Years = 30
Discount Rate = 5%
TOTAL 30-Year Present Value
S17,200
$0
577,200
Alternative No. 3 - (Vegetative Soil Cover) - EOD Area
Total Capital Costs
Annual (Sampling/ Analysis/O&M) Costs - Years 1-5 only: $32,300
Total 30-Year Present Value for Annual Costs
Years = 30
Discount Rate = 5%
TOTAL 30-Year Present Value
5159,200
5140,000
$299,200
Alternative No. 3 - (Soil Removal / Vegetative Soil Cover) - Debris Burial Area
Total Capital Costs
Annual (Samp ling/ Analysis/O&M) Costs - Years 1-5 only: 51,800
30-Year Present Value for Annual Costs
Years = 30
Discount Rate = 5%
TOTAL 30-Year Present Value1
S62,000
S8,000
570,000
Notes:
1) The Total 30-Year Present Value is the sum of the total capital costs and the 30-Year Present Value for
annual costs.
2.8.8 State Acceptance
The assessment of this criterion considered the State's preferences for or concerns about the
alternatives.
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The State concurs with the selected remedy. The State provided comments on the RI, FS,
Proposed Plan, and this ROD. Afte incorpor ng adequate responses to the comments into
the respective documents, the State : ncurrec h the remedy.
2.8.9 Community Acceptance
Comments offered by the public were used to assess the community acceptance of the
proposed alternative. The community expressed their concerns about the selected remedy
during the public comment period. The questions and concerns of the community are
discussed in detail in the Responsiveness Summary that is in Appendix B of the ROD.
2.9 SELECTED ALTERNATIVE
Based on the requirements of CERCLA, comparative analysis of the nine criteria, public
comments, and in consultation with EPA and the State, the Air Force has determined that the
selected alternative for the EOD Area is Alternative 3, Vegetative Soil Cover/Institutional
Controls. This alternative includes institutional controls in conjunction with a soil cover to
reduce potential risk. The selected alternative for the Debris Burial Area is Alternative 3,
Vegetative Soil Cover/Institutional Controls. This alternative uses access restrictions in
conjunction with a soil cover to reduce potential risk. Five-year review of the remedies for
both areas will be conducted to determine the effectiveness of the remedial actions.
For the EOD Area, components of Alternative 3 are:
Constructing an earth cover over the EOD Area;
Institutional controls for the EOD Area;
Long-term sediment sampling; and,
Long-term maintenance of earth cover.
Each item is discussed below.
Installation of Soil Cover
A soil cover is proposed only for those portions of the EOD Area that can naturally support
vegetation. These areas correspond to the areas at the EOD Area with the highest
concentrations of contaminants. Even in their natural state, some areas of the EOD Area
cannot support vegetation because of the presence of shale outcroppings, steep slopes, or both.
It is estimated that approximately one third (4.5 acres) of the EOD ea will require covering.
Prior to installation of the soil cover, those areas to receive cover v. ->e filled, graded, and
contoured to maintain stability, provide for positive drainage off the ^a, and prevent ponding
of water above previously active disposal areas. A soil cover of approximately 6 inches thick
will then be constructed over those areas. The cover material must be capable of sustaining
perennial vegetation. To control erosion of the cover, vegetation will be established over the
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new cover and other areas of the OU that are currently unvegetated or under vegetated. Both the
cover and vegetation will be maintained and periodically inspected until vegetation is established,
the cover has settled, and no further fill or erosion problems exist.
Institutional Controls
Institutional controls will be implemented to prevent human exposure to contaminated soil. These
controls will include: (1) issuing a continuing order to restrict onsite worker access to
contaminated soil, and restrict or control temporary construction activities unless proper
protective equipment is worn; (2) filing a notice with the State of South Dakota to recommend
denial of appropriation permit applications to install ground-water wells within the EOD Area
boundaries; (3) annotating base records in the event of property transfer.
A continuing order will be issued by the Installation Commander to restrict access to or
disturbance of the EOD Area as long as Ellsworth AFB owns the property. Specifically, it will:
Restrict or place limitations on the installation of any new underground utilities or
other construction activities in Areas 1 and 2; thus preventing accidental exposures
to construction workers.
Provide for the use of proper protective equipment, in the event that access
through the EOD Area cover is required.
Require that the integrity of the cover is maintained. Limit future land uses to non-
intrusive activities only (or activities that will not disturb the newly placed cover).
Maintenance of the cover will require development for standard operating
procedures (SOPs) to provide for inspections and repairs. To assist with the
institutional controls, a fence may be place around the Areas 1 and 2 and
authorized personnel would have access through a locked gate. Access would
only be allowed to perform monitoring well sampling and maintenance activities.
Warning signs would be posted to deter unauthorized access.
The continuing order also will mandate that, if the earth cover was ever removed or
destroyed, the area of attainment will be reevaluated to determine the need for a replacement
cover or other remedial action.
Continuing order requirements will be in effect as long as EAFB owns the property. In the
case of the sale or transfer of property within OU-8 by the United States to any other person
or entity, the Air Force will place covenants in the deed that will restrict access and prohibit
disturbance of the EOD Area or the remedial action without approval of the United States.
These covenants will be in effect until removed upon agreement of the State of South Dakota,
the U.S. Environmental Protection Agency, and the U.S. Air Force or their successors in
interest. The Air Force will also include in the deed the covenants required by section
120(h)(3) of the Comprehensive Environmental Response,
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Compensation and Liability Act (CERCLA), which include (1) a warranty that the United
States will conduct any remedial action found to be required by law after the date of the
transfer; (2) a right of access for the EPA and the Air Force or their successors in interest
to the property to participate in any response or corrective action that might be required
after the date of transfer. The right of access referenced in the preceding sentence shall
include the State of South Dakota for purposes of conducting or participating in any
response or corrective action that might be required after the date of transfer.
Long-Term Monitoring and Maintenance
V
A long-term monitoring program will be developed and implemented during remedial
action and is subject to approval of both EPA and SDDENR. Contaminant concentrations
in the sediment in the adjacent and downgradient drainages at OU-8 will be monitored to
evaluate the effectiveness of the existing cover and to determine if contaminants in the
surface soil have been transported into the drainages and accumulated to levels of concern.
A maintenance program will be established to ensure the long-term integrity of the existing
EOD Area conditions will be maintained. The maintenance program will include
development of SOPs to provide for inspections, repairs, and general maintenance of Areas
1 and 2.
For the Debris Burial Area, components of Alternative 3 are:
Constructing an earth cover over the Debris Burial Area;
Institutional controls for the Debris Burial Area; and, long-term
maintenance of earth cover.
Each item is discussed below.
The details of the items listed above are the same as to the respective items discussed for
the selected alternative for the EOD Area, except that the access restrictions for the Debris
Burial Area will consist of installing a temporary barbed wire fence only until vegetation is
established. This fence will serve to keep livestock out of the area until vegetation is
established. Also, there will be no long-term monitoring required under this alternative for
the Debris Burial Area.
These alternatives will meet the remedial action objectives and reduce the potential risk at
OU-8 by reducing the potential for future exposure to and mobility of contaminants in
surface soils. Figures 2-4 and 2-5 show areas where new earth cover will be placed for
each respective area. As agreed with between EAFB and the SDDENR, Area #1 will
receive a soil cover of approximately six inches and the soil cover at Area #2 will be
approximately 2 feet. These soil covers have been determined to be an appropriate amount
of soil to achieve to goals of the selected remediation alternative and meet ARSD Chapter
74:27:15 of the South Dakota Waste Management Regulations.
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For both respective areas, Alternative 3 will achieve risk reduction by limiting exposure to
contaminants present in surface soils and will significantly reduce the potential for future
migration of contaminants by reducing the mobility of the chemicals of concern in soils
through containment and long-term erosion maintenance. The selected alternatives will be
protective of human health and the environment and will comply with ARARs.
2.10 STATUTORY DETERMINATIONS
The selected remedies meet the statutory requirements of CERCLA as amended by SARA.
These requirements include protection of human health and the environment, compliance
with ARARs, cost effectiveness, and utilization of permanent solutions and alternative
treatment technologies to the extent practicable. The statutory preference for treatment is
not satisfied. Containment, by definition, does not attempt to reduce the toxicity or
volume of potentially hazardous materials; rather, it reduces the likelihood of exposure to
these materials by preventing the movement of materials beyond the boundaries of OU-8
and preventing direct contact with potentially hazardous materials. The selected remedies
represent the best balance of tradeoffs among the alternatives considered, with respect to
pertinent criteria, given the scope of the action.
The manner in which the selected remedy meets each of these requirements is discussed in
the sections below.
2.10.1 Protection of Human Health and the Environment
The selected remedies address health and environmental issues that were identified in the
OU-8 RI report. Specifically, the cover alternative (with institutional controls) for the
EOD Area:
Reduces potential exposure to contaminated surface soil.
Reduces the migration potential of contaminated surface soil into adjacent
drainages and potentially off Base.
Reduces the potential infiltration of contaminants to the ground water.
Prevents unauthorized access to the area by installing a perimeter fence and
posting restricted access signs.
Provides for long-term monitoring of sediment to identify potential future
risks associated with OU-8.
Places land and ground-water use restrictions on the site.
Specifically, the soil cover alternative (with institutional controls) for the Debris Burial
Area:
Reduces potential exposure to surface debris and chemical in the surface
soil.
Reduces the migration potential of contaminated surface soil into adjacent
drainages and potentially off Base.
Reduces the potential infiltration of contaminants to the ground water.
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Final Record of Decision Operable Unit 8
Ellsworth Air Force Base, South Dakota
Places land and ground-water use restrictions on the site.
10.2 Compliance with ARARs
The only potential chemical-specific ARARs are the State of South Dakota Remediation
Criteria for Petroleum-Contaminated Soils. Detected levels of petroleum-related
compounds do not exceed State ARARs at OU-8. Action-specific ARARs potentially
applicable to OU-8 include State regulations pertaining to closure of solid waste disposal
sites (ARSD 74:27:15). There are no action-specific ARARs for Area 1. The State has
agreed that Alternative 3 will be sufficient in complying with the substantiate
requirements of these regulations for Area 2. There are no location-specific ARARs for
OU-8.
2.10.3 Cost Effectiveness
The selected remedies provide overall effectiveness in reducing human health risks relative
to their costs. The presumptive remedy process ensures cost-effective remedies are
chosen. The soil covers ensure containment of the contaminated soils and debris.
2.10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies to
the Extent Possible
EPA has established that installing a proper cover has proven effective in containing
landfill contents. Although the EOD and Debris Burial Areas are not landfills, the areas
lend themselves to the presumptive remedies preference for containment (for waste left in
place). The alternatives for both areas provide long-term prevention of exposure to
contaminants and waste debris. The alternative for Area 1 prevents unauthorized access
to the area and provides for long-term sediment monitoring to detect potential movement of
chemicals from the area. A review will be conducted five years after the commencement
of the remedial action to ensure the remedies continue to provide adequate protection of
human health and the environment.
2.10.5 Preference for Treatment as a Principal Element
Treatment of the contents at Area 1 or Area 2 is not supported based on the findings of the
RI for OU-8. No identifiable hot spots were detected that would warrant removal and/or
s.eparate treatment, and the risks associated with these areas can be addressed by installing
a cover to eliminate exposure and reduce erosion and by restricting access to the site.
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES
The selected action for the EOD Area, the cover alternative, is similar to the preferred
alternative presented in the Final Proposed Plan for OU-8. However, the extent of the new
cover in this area has been reduced from that originally proposed in the Proposed Plan.
Since the EOD Area is in rugged terrain with steep slopes and numerous shale
outcroppings are present, there are some areas of the EOD Area that cannot naturally
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Final Record of Decision Operable Unit 8
Ellsworth A ir Force Base, South Dakota
support vegetation because they cannot hold cover soil. Contamination is not present in
these areas. It is not technically feasible to cover and vegetate these areas. Because of
geology and low risk associated with this area, new cover will be placed only over those
areas of the EOD Area where vegetation can be supported. Because of activities at the
EOD Area, vegetation is not growing or is sparse. Since contamination is primarily in the
topsoil, these areas generally correspond to the areas of highest contamination. The
Proposed Plan for OU-8 had proposed placing cover over the entire area.
The selected alternative for the Debris Burial Area, the cover alternative, is the same as the
preferred alternative presented in the Final Proposed Plan for OU-8 except that there will
be no removal of surface debris (small caliber shell casings). Since there was no risk
associated with debris, the State of South Dakota has concurred that covering the debris
with a six-inch soil cover will be sufficient in this area.
The changes to the proposed alternatives have resulted in significant savings in cost to
complete them. Because of this, costs presented in the Final Proposed Plan for OU-8 are
significantly higher than the costs presented in the ROD.
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Final Record of Decision Operable Unit 8
Ellsworth Air Force Base, South Dakota
TABLE 2-1 EVALUATION OF FEDERAL AND STATE ARARS THAT APPLY TO OU-8, ELLSWORTH AFB, SOUTH DAKOTA
Potentially Applicable or Relevant and Appropriate Federal Standards. Requirements. Criteria and Limitations
Standard Requirement, Criteria,
or Limitation
Safe Drinking Water Ad of 1986
National Primary Drinking Water
Regulations
National Secondary Drinking Water
Standards
Maximum Contaminant Level
Goals
Clean Water Act of 1977
Water Quality Criteria
Clean Air Act of 1983
National Primary and Secondary
Ambient Air Quality Standard
National Emission Standards for
Hazardous Air Pollutants
Solid Waste Disposal Act as amended by
Resource Conservation and Recovery Act
of 1976
Land Disposal Restrictions
Guidelines for the Land Disposal of Solid
Waste
Citations
42 USC 300g
40 CFR Part I4I.II-I2
40CFRPart 1 43 03
40CFRPart I4I.50&
Pub. L. No. 99-330, 100 Stat. 642 (1986)
33 USC 1251-1376
40CFRPart 131
42 USC 7401
40 CFR Part 50.1-6, 8,9,11,12, and
Appendices A, H, J, K
40 CFR Part 61. 01
42 USC 6901
40 CFR Part 268
40 CFR Part 24 1.1 00-21 3
Description
Specifies maximum chemical contaminant
levels (MCLs) of public water systems.
Establishes secondary maximum
contaminant levels (SMCLs) for public
water systems. These arc federally non-
enforceable standards which regulate
contaminants in drinking water that
primarily affect the qualities.
Establishes drinking water quality goals set
at levels of unknown or anticipated adverse
health effects, with an adequate margin of
safety.
Sets criteria for water quality based on
toxicity to aquatic organisms and human
health.
Establishes national primary and secondary
ambient air quality standards to protect
public health and welfare.
Establishes regulatory standard for specific
air pollutants.
Identifies hazardous wastes that are
restricted from land disposal and defines
those limited circumstances under which
a prohibited waste may continue to be
land disposed
Establishes requirements and
procedures for the disposal of solid
waste.
ARAR Type
Chemical
Chemical
Chemical
Chemical
Action
Action
Action
Action
Applicability
Relevant and appropriate for Federal
Class II Aquifer.
Relevant and appropriate.
Relevant and appropriate.
Relevant and appropriate. Aquifer
may be a Federal Class HA (discharge
to surface water).
Relevant and Appropriate.
Relevant and Appropriate.
Relevant and Appropriate.
Relevant and appropriate.
2-24
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Final Record of Decision Operable Unit 8\
Ellsworth Air Force Base, South Dakota
TABLE 2-1 (Cont.) EVALUATION OF FEDERAL AND STATE ARARS THAT MAY APPLY TO OU-8, ELLSWORTH AFB, SOUTH DAKOTA
Standard Requirement, Criteria,
or Limitation
Resource Conservation and Recovery Act
of 1976
Hazardous Waste Management
System: General
Identification and Listing of
Hazardous Wastes
Standards Applicable to
Generators of Hazardous Wastes
Standards Applicable to
Transporters of Hazardous
Wastes
Toxic Substances Control Act (TSCA)
Citations
40 CFR Part 260
40 CFR Part 261
40 CFR Part 262
40 CFR Part 263
40 CFR Part 761 1
Description
Establishes definitions as well as
procedures and criteria for modification
or revocation of any provision in 40 CFR
Parts 260-265
Defines those solid wastes which are
subject to regulations as hazardous
wastes under 40 CFR Parts 262-265
Establishes standards for generators of
hazardous waste
Establishes standards which apply to
persons transporting hazardous waste
within the U.S. if the transportation
requires a manifest under 40 CFR Part
262
Substances regulated under this rule
include, but are not limited to, soils and
other materials contaminated as a result
of spills
ARAR Type
Action
Action
Action
Action
Action
Applicability
Applicable for identifying hazardous
waste during soil placement at OU-
8.
Applicable for identifying hazardous
waste during soil placement at OU-
8.
Applicable to alternatives relating to
removal or offsite transport of a
hazardous material.
Applicable for any transport of
hazardous materials offsite.
Applicable
F: \PROJ\603 7886\FS\OU8. ROD\FINAL\OU8ROD. FNL
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May 7. 1996
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Final Record of Decision Operable Unit 8
Ellsworth Air Force Base, South Dakota
TABLE 2-1 (Cont.) EVALUATION OF FEDERAL AND STATE ARARS THAT MAY APPLY TO OU-8, ELLSWORTH AFB, SOUTH DAKOTA
Potentially Applicable or Relevant and Appropriate State Standards. Requirements. Criteria, and Limitations
Standard Requirement. Criteria.
or Limitation
South Dakota Air Pollution Control
Regulations
South Dakota Waste Management
Regulations
South Dakota Waste Management
Regulations
South Dakota Was*' ""-rf.nent
Regulations
South Dakota Waste Management
Regulations
South Dakota Water Quality Standards
South Dakota Remediation Criteria for
Petroleum-Contaminated Soils
South Dakota Ground Water Standards
Citations
742601 09. 24. 25. 26-28
74:27:03:11
7427:0906
74:27 15
74:2824:01
74:03:04:02.10
74:03:32
74:03:15
Description
Establishes permit requirements for
construction, amendment, and operation
of air discharge services
Defines requirements for closure of solid
waste disposal facilities
Defines criteria for permit application for
other solid waste TSD facilities
Establishes standards for landfill closure
and postclosure monitoring
Establishes standard for transporters of
waste
Defines use of Boxelder Creek and
certain tributaries.
Establishes requirements for the
remediation of soil contaminated with
petroleum products.
Defines ground water classifications by
beneficial use and sets chemical
standards.
ARAR Type
Action
Action
Action
Action
Action
Action
Chemical
Chemical
Applicability
Relevant and appropriate.
Relevant and appropriate.
Relevant and appropriate.
Relevant and appropriate
Relevant and appropriate
Relevant and appropriate.
Relevant and appropriate for
evaluating acceptable levels of
petroleum products in the soil.
Relevant and appropriate in
evaluating the beneficial use of
Impacted groundwater.
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May 7, 1996
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Final Record of Decision Operable Unit 8
Ellsworth Air Force Base, South Dakota
3.0 LIST OF ACRONYMS AND ABBREVIATIONS
ACC: Air Combat Command
AFB: Air Force Base
ARARs: Applicable or Relevant and Appropriate Requirements
BTEX: Benzene, toluene, ethylbenzene, xylene
CERCLA: Comprehensive Environmental Response, Compensation and Liability Act
COC: Chemicals of Concern
CRP: Community Relations Plan
C^A: Clean Water Act
EAFB: Ellsworth Air Force Base
EOD Area: Explosives Ordnance Disposal Area
EPA: Environmental Protection Agency
FAWQ: Federal Ambient Water Quality
IRP: Installation Restoration Program
MCL: Maximum Contaminant Levels
Mg/1: Micrograms per liter
mg/1: Milligrams per liter
NCP: National Oil and Hazardous Substances Contingency Plan
NPL: National Priorities List
OU: Operable Unit
PAH: Poly nuclear Aromatic Hydrocarbon
pg/g Picogram per gram
ppm: Parts per million by weight
RA: Remedial Action
RAB: Restoration Advisory Board
RAOs: Remedial Action Objectives
RCRA: Resource Conservation and Recovery Act
RI/FS: Remedial Investigation/Feasibility Study
SARA: Superfund Amendments and Reauthorization Act
SACM: Superfund Accelerated Cleanup Model
SVOC: Semivolatile Organic Compound
TAL: Target Analyte List
TCE: Trichloroethy lene
TCL: Target Compound List
TIC:" Tentatively identified compound
TPH: Total Petroleum Hydrocarbons
USAGE: United States Army Corps of Engineers
USAF: United States Air Force
VOC: Volatile Organic Compound
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3-1
May 7, 1996
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Final Record of Decision Operable Unit 8
Ellsworth Air Force Base, South Dakota
APPENDIX A
FIGURES
F:\PROJ\6037886\FS\OU8.ROD\FINAL\OU8ROD.FNL May 7, 1996
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MINNESOTA
NORTH DAKOTA
_-
SOUTH DAKOTA
ELLSWORTH AFB
Rapid City
Sccie in Miles
APPROXIMATE
EIL_L_SWORTH
AIR FORCE BASE:
ELLSWORTH AFB
RAPID CITY, SOimi DAKOTA
AREA LOCATION MAP
ROJEC: M
DESIGNED BY
DRAWN BY
MRG
CHECKED BY
SCALE
AS SHOWN
DATE
DEC 95
PROJECT NO
60278.93
1GURE:
2-1
-------
DEBRIS I
BURIAL I
AREA j
I
I
OU-1
OU-2
CU-5
OU--
CU-5
CU-5
CU-7
00-3
CU-9
CU-'C"
OU-11
CU-12
FiRE PROTECTION TRAINING
AREA (FT-01)
LANDFILLS 1 & 5 (LF-02)
LANDFILL 2 (LF-G3)
LANDFILL 2 (LF-04"
LANDFILL * (LF-05
LANDFILL 5 (LF-06)
LOW LEVEL RADIATION WASTE BURIAL AREA fRW-07)
EXF1CSVE ORDNANCE DISPOSAL AREA * PRAMfTCL SRLL
OLD AUTO HOE5Y SHOP AREA (OT-15)
NORT-' HANGAR COMPLEX (ST-19)
SASEWIDE GROUND WATER
HARDFiLL NO. 1
ELLSWORTH
FORCE: EASE
ELLSWORTH AFB
RAPID CTY, SCLfTW DAKOTA
SITE LOCATION MAP
<-
~ <
RCJEC: uca
DESIGNED BY
DRAWN BY
STAFF
CHECKED 3Y
AS SHOWN
DATE
DEC 95
PRC,'E:T NC
60378.93
RGURE:
2-2
-------
v V UU \\
^^AxTSgr^
»Ui«M<
y////\ APPROXIMATE LOCATION
OF HERBICIDE SPILL
SURFACE DRAINAGE
EASE BOUNDARY FENCE
TOPOGRAPHIC Ei_EVATION
-ABOVE MSL
CONTOUR INTERVAL=10f
OF OU-8 DEBRIS
BURIAL STUDY AREA
(AREA 2)
ELLSWORTH AFB
RAPID crrx scum DAKOTA
EL.L.SWORTM
AIR FORCE:
OU-8 SHI AREA MAP
OJECT NO
60378.93
-------
N
EXTENT OF OU-8 1
EXPLOSIVE ORDNANCE |
DISPOSAL_ STUDY AREA I
i
I X\___>_GA1E i
1993/94 Rl MONITORING
WELL/SOIL BORING LOCATION
©
1993/94 Rl FlCin SCREEN/
SOIL GORING LOCATION
1993/94 Rl SURFACE SOIL
CRAB SAMPLE
APPROXIMATE LOCATION OF
PROMETON (PRAMITOL 25E) SPILL
1 PRIMARY AREA OF NEW COVER
SURFACE DRAINAGE
BASE BOUNDARY FENCE
TOPOGRAPHIC ELEVATION ABOVE
MSL - CONTOUR INTERVAL=10'
SCALE
EL.L.SWORTM
AIR FORCE BASE
ELLSWORTH AFB
WC OTY. SOUTH DAKOTA
EDO AREA
ALTERNATIVE NO. 3
VEGETATFVE COVER/
INSTITUTIONAL CONTROLS
JSS
PROJECT MCR.
FEB 96
SCALE
AS SHOWN
2-4
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Final Record of Decision Operable Unit 8
Ellsworth Air Force Base, South Dakota
APPENDIX B
RESPONSIVENESS SUMMARY
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Final Record of Decision Operable Unit 8
Ellsworth Air Force Base, South Dakota
Responsiveness Summary
^Remedial Action at Operable Unit Eight
Ellsworth Air Force Base, South Dakota
1. Overview
The United States Air Force (USAF) established a public comment period from December 28,
1995 to January 27, 1996 for interested parties to review and comment on remedial alternatives
considered and described in the Proposed Plan for Operable Unit 8 (OU-8). The Proposed Plan
w£s prepared by the USAF in cooperation with the U.S. Environmental Protection Agency
(USEPA) and the South Dakota Department of Environment and Natural Resources (SDDENR).
The USAF also held a public meeting at 7:30 p.m. on January 11, 1996 in the Box Elder Middle
School at Box Elder to outline the proposed remedy to reduce risk and control potential hazards at
the Operable Unit (OU).
The Responsiveness Summary provides a summary of comments and questions received from the
community at the public meeting and during the public comment period as well as the USAF's
responses to public comments.
The Responsiveness Summary is organized into the following sections:
Background on Community Involvement
Summary of Comments and Questions Received During the Public Comment Period
and USAF Responses
Remaining Concerns
2. Background on Community Involvement
On August 30, 1990 EAFB was listed on the USEPA's National Priorities List (NPL). A Federal
Facilities Agreement (FFA) was signed in January 1992 by the Air Force, EPA, and the State and
went into effect on April 1, 1992. The FFA establishes a procedural framework and schedule for
developing, implementing, and monitoring appropriate response actions for EAFB.
Community relations activities that have taken place at EAFB to date include:
FFA process. After preparation of the FFA by the USAF, EPA, and SDDENR,
the document was published for comment. The FFA became effective April 1,
1992.
Administrative Record. An Administrative Record for information was
established in Building 8203 at EAFB. The Administrative Record contains
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Final Record of Decision Operable Unit 8
Ellsworth Air Force Base, South Dakota
information used to support USAF decision-making. All the documents in the
Administrative Record are available to the public.
Information repositories. An Administrative Record outline is located at the
Rapid City Library (public repository).
Community Relations Plan (CRP). The CRP was prepared and has been accepted
by EPA and the State of South Dakota and is currently being carried out. An
update to this plan will be prepared in 1996.
Restoration Advisory Board (RAB). The RAB has been formed to facilitate
public input in the cleanup and meets quarterly. In addition to USAF, EPA, and
South Dakota oversight personnel, the RAB includes community leaders and local
representatives from the surrounding area.
Mailing list. A mailing list of all interested parties in the community is maintained
by EAFB and updated regularly.
Fact sheet. A fact sheet describing the status of the IRP at EAFB was distributed
to the mailing list addressees in 1992.
Open house. An informational meeting on the status of the IRP and other
environmental efforts at EAFB was held on May 6, 1993. An open house was held
November 16, 1995 in conjunction with the Restoration Advisory Board meeting.
Information on the status of environmental efforts at EAFB was provided.
Newspaper articles. Articles have been written for the Base newspaper regarding
IRP activity.
The Proposed Plan for this remedial action was distributed to the mailing list addressees for their
comments, and additional copies of the Proposed Plan were available at the January 11, 1996
public meeting. A transcript of comments, questions and responses provided during the public
meeting was prepared.
3. Summary of Comments and Questions Received During the Public Comment Period
and USAF Responses
Part I - Summary and Response to Local Community Concerns
Review of the written transcript of the public meeting did not indicate community objections to the
proposed remedial action. No written comments were received during the public comment period.
Part II - Comprehensive Response to Specific Technical, Legal and
Miscellaneous Questions
There were no comments or questions regarding OU-8 presented during the public meeting.
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