Superfund Record of Decision Fort Riley Pesticide Storage Facility OU 2 Junction City KS


                                    EPA/ROD/R07-97/142
                                    1997
EPA Superfund
     Record of Decision:
     FORT RILEY
     EPA ID: KS6214020756
     OU02
     JUNCTION CITY, KS
     09/29/1997

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RECORD OF DECISION

PESTICIDE STORAGE FACILITY

OPERABLE UNIT 002

FORT RILEY, KANSAS

SEPTEMBER 1997

Attached is the Record of Decision (ROD) for OU2, Pesticides Storage Facility(PSF), at Fort Riley,
Kansas. I believe that this No Action ROD is protective of human health and the environment and
recommend you sign it. This is a targeted commitment for fiscal year 1997. Listed below are factors to
consider before signing the document.

A removal action was done the fall of 1993, which cleaned up the site for industrial use, which
is also the current and expected future land use for the site.

The project manager for the state of Kansas is in agreement with this ROD, and has prepared a
letter of concurrence for signature for the state's management.

At this time, a deed restriction is not possible for this site. Fort Riley has indicated there
is no legal documentation in the court house for this facility.

Sampling of the groundwater does not show the existence of pesticides, therefore there is no
current evidence of a pathway to the groundwater from the PSF site.

Regional Counsel concurs with this ROD as to the requirements of the NCP.

If you need addition information or have any guestions, please contact Bob Koke at x7468.

Attachment

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SEP 29 1997

MEMORANDUM

SUBJECT: ROD for Fort Riley, KS

FROM: Michael J. Sanderson, Director
Superfund Division

TO: Dennis Grams, P.E.
Regional Administrator

Attached is the Record of Decision (ROD) for OU2, Pesticides Storage Facility(PSF), at Fort Riley,
Kansas. I believe that this No Action ROD is protective of human health and the environment and
recommend you sign it. This is a targeted commitment for fiscal year 1997. Listed below are factors to
consider before signing the document.

A removal action was done the fall of 1993, which cleaned up the site for industrial use, which
is also the current and expected future land use for the site.

The project manager for the state of Kansas is in agreement with this ROD, and has prepared a
letter of concurrence for signature for the state's management.

At this time, a deed restriction is not possible for this site. Fort Riley has indicated there
is no legal documentation in the court house for this facility.

The ROD reguires a five-year review, since the site has not been cleaned to residential
standards. The five-year review and the Fort Riley Master Plan will have the effect of an
institutional control on future land use.

Sampling of the groundwater does not show the existence of pesticides, therefore there is no
current evidence of a pathway to the groundwater from the PSF site.

Regional Counsel concurs with this ROD as to the reguirements of the NCP.

If you need addition information or have any guestions, please contact Bob Koke at x7468.

Attachment

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           LEAD AND SUPPORT AGENCY ACCEPTANCE OF THE RECORD  OF  DECISION,
                   OPERABLE UNIT 002, PESTICIDE STORAGE  FACILITY
                                 FT. RILEY, KANSAS

    Signature Sheet for Record of Decision for Operable  Unit 002,  Pesticide  Storage Facility,  Fort Riley,
Kansas, Final Action.

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                               1.0 DECLARATION

SITE NAME AND LOCATION

    Pesticide Storage Facility, Operable Unit 002
    Federal Facility Site - Fort Riley, Kansas

STATEMENT OF BASIS AND PURPOSE

    This Record of Decision document presents the selected remedial action for the Pesticide Storage
Facility, Operable Unit 002, at Fort Riley, Kansas, chosen 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 to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan  (NCP).  This decision is based on the Administrative
Record for the site.

    This remedy was chosen by the Department of the Army and Fort Riley, in consultation with the United
States Environmental Protection Agency, Region VII (USEPA) and the Kansas Department of Health and
Environment (KDHE).  The State of Kansas concurs with the selected remedy via a letter of concurrence.

DESCRIPTION OF THE SELECTED REMEDY

    The selected remedy for the Pesticide Storage Facility, Operable Unit 002, at Fort Riley is No
Further Action.  A Removal Action in which contaminated soils were excavated, transported, and disposed
off-site was completed in 1994.  Based upon current and projected industrial land use at the site and the
populations that may be exposed to site contamination, it has been  determined that the site does not
pose a significant threat to public health, welfare,  and the  environment.

    If a significant change in land use at the PSF is proposed by Fort Riley, or if any portion of the
site property is transferred or leased to a non-government entity, Fort Riley will notify Region VII of
the U.S. Environmental Protection Agency (EPA) and the Kansas Department of Health and Environment  (KDHE)
in writing of the proposed change in land use or transfer of lease of the property or a portion of the
property.  If the change in land use is determined to be a major change in land use, a reevaluation of
the remedy decision will be reguired.  Depending upon the nature of the transfer or lease of the site
property, EPA and/or KDHE may reguire Fort Riley to reconsider the no further action decision selected in
this Record of Decision, which may reguire the implementation of additional response actions, including
institutional controls, prior to the transfer or lease of site property.

DECLARATION STATEMENT

    At this time, no further remedial action is necessary for Operable Unit 002, the Pesticide Storage
Facility to ensure protection of human health and the environment.  Section 300.430(f)(4)(ii) of the
National Oil and Hazardous Substances Pollution Contingency Plan  (NCP) states that if a remedial action
is selected that results in hazardous substances, pollutants or contaminants remaining at a site above
levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action
no less often than every five years after initiation of the selected remedial action.  Although the
decision reached in the Record of Decision is no further action, this decision is based upon current and
reasonably projected land use and exposures.  However, hazardous substances, pollutants or contaminants
may remain at the site above levels that would allow for unlimited use and unrestricted exposure.
Therefore, the five year review will apply to this site.


                  LEAD AND SUPPORT AGENCY ACCEPTANCE OF THE RECORD OF DECISION,
                                OPERABLE UNIT 002, PESTICIDE STORAGE FACILITY
                                                  FT. RILEY, KANSAS

    Signature Sheet for Record of Decision for Operable Unit 002, Pesticide Storage Facility, Fort Riley,
Kansas, Final Action.

    Colonel Kent D. Thomas                                        Date
    Garrison Commander, Fort Riley
    United States Department of the Army

    Dennis Grams, P.E.                                            Date
    Regional Administrator
    U.S. Environmental Protection Agency - Region VII
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                                    2.0 DECISION SUMMARY

2.1 SITE NAME, LOCATION, AND DESCRIPTION

Pesticide Storage Facility, Operable Unit 002
Fort Riley, Kansas

    Fort Riley (the installation) is situated along the north bank of the Kansas and Republican Rivers in
Riley and Geary counties in north-central Kansas (Figure 2-1).   The installation is comprised of
approximately 101,000 acres.  It lies within the Osage Plains section of the Central Lowlands
physiographic province.  The general topography around Fort Riley consists of plains incised by steep
drainage features.  Terrain on the installation varies among the following features:   (1) narrow,
alluvial bottomlands and wide, meandering floodplains and associated terraces along the Republican and
Kansas Rivers; (2) steep slopes and hilly relief, and (3) flat-lying or slightly dipping uplands.

    The Pesticide Storage Facility (PSF) site (the site) is situated on a terrace on the north side of
the site covers about 2/3 of an acre around Building 348 and is located in the Main Post Area.  The area
of investigation is indicated on Figure 2-2.  The site includes a portion of the Public Works (formerly
Directorate of Engineering and Housing  [DEH])  Storage Yard, which is surrounded by a fence and has
secured access.  The site extends south of Dickman Avenue to the south-central edge of the Main Post
cantonment area and southeast across the railroad tracks.  The entire site is within a zone designated as
Industrial use in the Fort Riley Master Plan.    (See attached Main Post area land use zone map.)
Topographic elevations at the site are about 25 feet higher than the Kansas River.  The ground surface
east of the Building 348 fence slopes downward toward the east-southeast at a grade of approximately 10
percent.  There is an abrupt slope change just east of the PSF fence line.

    Surface run-off across the site generally flows east - southeast as sheet flow, following the
topography of the site.  After flowing around Buildings 345, 346, 347, and 348, the surface run-off is
directed to a 12-inch corrugated metal pipe culvert that discharges via overland drainage into the
rock-lined channel east of the yard area.  The lined drainage ditch runs from Dickman Avenue to the
railroad tracks southeast of the site.  The sides of the drainage ditch are constructed of cemented
limestone blocks.  Surface run-off in this channel proceeds southward under the railroad tracks and then
flows into an unnamed tributary leading to the Kansas River.

2.2 SITE HISTORY AND REMEDIAL ACTIVITIES

    Fort Riley was established in 1852, as an outpost near the confluence of the Republican and Smoky
Hill Rivers.  Since its inception, Fort Riley has continually served as a major center of military
education and readiness, at times including a population of more than 20,000 military residents and
civilian employees.  The Fort Riley reservation historically has functioned both as a small municipality
and light industrial complex.  Solid waste disposal (landfilling),  wastewater treatment and discharge,
facilities maintenance and construction, pesticide and herbicide usage, and electrical eguipment
installation, storage, and repair, are among the environmentally significant activities at Fort Riley.
Fort Riley's function as a military training,  eguipment supply, and maintenance center historically has
reguired management and disposal of wastes associated with these activities.

    Building 348 was constructed in 1941 as a general purpose warehouse.  Fort Riley records do not
indicate when pesticides were first stored in Building 348.  However, interviews with Fort Riley
personnel reveal that Building 348 had been used for pesticide storage since at least 1973.  Prior to the
late 1970s, the maintenance/storage yard east of and adjacent to Building 348 was used to wash down
vehicles and spray eguipment used for pesticide applications.  Since at least 1976, the majority of
pesticide application at Fort Riley has been performed by outside contractors who were not allowed to use
the PSF site.  During 1988, several polychlorinated biphenyl (PCB)- containing electrical transformers
were stored in containers outside the southeast corner of Building 348.  Other items previously stored at
the PSF site include paint, pesticides/herbicides,  pressure-treated lumber, and various general
improvement materials and eguipment.

    Pursuant to Section 105 of the Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA),  Fort
Riley was proposed for inclusion on the National Priorities List (NPL) on July 14, 1989.  There are
currently five identified Operable Units (OUs)at Ft. Riley.  Two sites at Fort Riley, the PSF site and
Southwest Funston Landfill, were combined by the U.S.   Environmental Protection Agency  (USEPA) as one
site for purposes of Hazard Ranking System  (HRS) scoring.  The USEPA reasoned that both contaminant
sources potentially affect the same shallow aguifer and target populations.  The installation was placed
on the NPL as of October 1990, with a combined score of 33.79 on the HRS.   (A HRS score of 28.5 is needed
for inclusion on the NPL.)
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    The Department of the Army - Fort Riley, the USEPA Region VII, and the State of Kansas Department of
Health and Environment  (KDHE) negotiated a Federal Facilities Agreement  (FFA) for Fort Riley, Docket No.
VII-90-F-0015, also referred to as the Interagency Agreement  (IAG), which became effective on June 28,
1991.  The FFA specifically reguires that the PSF site be addressed through the Remedial
Investigation/Feasibility Study (RI/FS) process.  Consistent with the  National Contingency Plan  (NCP)
°300.415, the FFA also allows the Army to perform Removal  Actions concurrent with RI/FS activities.  The
following documents were prepared in accordance with the FFA:

              RI  Report (December  1993)
       •      Removal Action Engineering Evaluation/Cost Analysis Report (EE/CA) (August 1993)
       •      Removal Action Memorandum (December 1993)
              RI  Addenda (June 1997)
              Proposed Plan (July  1997)

    Site contamination at the PSF site was first revealed by Army pesticide use monitoring studies
conducted prior to 1990.  Fort Riley initiated planning of the RI/FS in 1990 during the development of
the FFA.  Field activities began in the early spring of 1992.  The results of the RI and a Baseline Risk
Assessment (BLRA) were presented in the RI Report.

    Concurrent with the performance of the RI and BLRA activities, the opportunity to perform a
non-time-critical Removal Action addressing contaminated soils was recognized.  An EE/CA was performed
to:   (1) determine if a Removal Action was appropriate to protect human health and the environment;  (2)
identify, evaluate, and recommend options for a Removal Action which could be incorporated into a
permanent solution to remediate the site; and (3) develop a remedy that meets the occupational safety and
health reguirements of site workers and allows continuing use of the site.

    The public comment period for the EE/CA was held August 17, through September 16, 1993.  A public
meeting was held at Fort Riley on September 7, 1993.  No comments were received during the public comment
period.  Subseguent to the finalization of the EE/CA, the Removal Action Memorandum was signed.  The
Action Memorandum Decision was to excavate and dispose of contaminated soil off-site.  The USEPA and KDHE
concurred with the Removal Action.

    The initial Removal Action Goals (goals), presented below, were generated from exposure scenarios for
future site workers developed in the BLRA.  These goals were extremely  conservative, as they were based
on a carcinogenic risk level of 10 -6 and the assumption that 100 percent of the chemical in contact with
the skin would be absorbed.  Additional exploratory sampling of the site revealed a greater than
anticipated area of contamination based on the initial Removal Action Goals, a factor which would
significantly increase the cost for remediation.  With the exception of heptachlor, which was not a "risk
driver", the Removal Action Goals for the pesticides were recalculated using more realistic dermal
absorption factors.  The Removal Action Goals for arsenic were revised based on results of a background
study.  These revised Goals are presented below.

                              Revised Absorption Factors and Removal Action Goals

    CONSTITUENT                     ACTION MEMORANDUM                   REVISED GOALS
                                          GOALS
                                  Absorption     Removal         Absorption    Removal Action
                                    Factor       Action             Factor       Goal  (mg/kg)
                                               Goal  (mg/kg)

    Chlordane                         100%        0.17                10.9%         1.58
    DDT, ODD, DDE                     100%        0.66                37.8%         1.73
    Dieldrin                          100%        0.014               10.9%         0.127
    Heptachlor                        100%        0.050                100%         0.050
    Arsenic                           100%        0.12                  NA          7.1(1)

    References for absorption factors per Agency for Toxic Substances and Disease Registry (ATSDR),
    1987 - 1993
    NA   - Not applicable
     (1)  - Removal Action Goal of background soil concentrations was established.

    During performance of the Removal Action, the actual excavation limits were guided by  sampling the
sidewalls and bottom of the excavations to determine if the action levels had been met.  A total surface
area of less than ^> acre was excavated to a depth of between 1 and 8 feet below the land surface.  A
total of approximately 2,700 tons of excavated soils was taken to an approved off-site landfill for
disposal.  The excavations were backfilled to approximately their original elevations.  Vegetation was
reestablished to restore the site for unrestricted use as an eguipment and material storage area.  The
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Removal Action was completed in June 1994.

    An RI Addenda  (dated June 1997) documents the Removal Action, presents a residual risk assessment of
the site, presents a statistical comparison of potential chemicals of concern in groundwater to
background concentrations, and identifies applicable or relevant and appropriate reguirements  (ARARs) for
the site.  The residual risk assessment is based on concentrations remaining in the soil after the
Removal Action.

    The Proposed Plan  (dated July 1997) described the preferred remedy for the PSF site to be No Further
Action and provided the rationale for this preference.  As a companion to the RI report, the Proposed
Plan was provided to inform the public of Fort Riley's, USEPA Region VII's, and KDHE's preferred remedy
based on the Administrative Record and solicit public comments pertaining to the preferred remedy.  The
Administrative Record is the set of supporting information used to determine the preferred alternative.

2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION

    The RI/FS process was conducted in accordance with CERCLA reguirements to document the comprehensive
remedial activities and proposed remedial plan for the PSF site.  Primary documents developed during the
RI/FS process have been made available for public review as part of the Administrative Record file at the
Fort Riley Directorate of Environment and Safety, Building 407.  These reports were also made available
to potentially affected persons and to the public in the following information repositories:  Dorothy
Bramlage Public Library, Manhattan Public Library, and Clay Center Carnegie Library.

    Notices of availability of these documents and the notice for the public meeting to discuss the
Proposed Plan were published in the Manhattan Mercury and the Junction City Daily Union newspapers on
August 24, 25, and 26, 1997, and in the Fort Riley Post on August 29, 1997.

    A public comment period for this remedial action was declared from August 24, 1997, through September
22, 1997, to provide a reasonable opportunity for comment and to disseminate information regarding the
Proposed Plan.

    An availability session was held at the Fort Riley community club, Riley's Restaurant and Event
Center, Building 446, on September 4, 1997.  At this meeting, representatives from the U.S. Army, KDHE,
and USEPA were available to inform the public of the preferred alternative and to record public comments.
No members of the public attended the availability session.  All public participation reguirements of
CERCLA Sections °113(k) and °117 were met with the actions described above.

    This decision document presents the selected remedial action for the PSF site, Operable Unit 002 at
Fort Riley, Kansas, which was chosen in accordance with CERCLA, as amended by SARA and, to the extent
practicable, the NCP.  The decision for this site is based on the Administrative Record.

2.4 SCOPE AND ROLE OF OPERABLE UNIT

    As with many Superfund sites, the issues at Fort Riley are complex.  As a result,  five OUs have been
identified at the site:

              OU001 - Southwest Funston Landfill
              OU002 - Pesticide Storage Facility
              OU003 - Dry Cleaning Facility
              OU004 - Marshall Army Airfield Former Fire Training Area (MAAF-FFTA)
              OU005 - 354 Area Groundwater Solvent Detections Site

    This Record of Decision addresses OU002, Pesticide Storage Facility (PSF).

    The evaluation of contamination at the PSF site addressed the soils, groundwater,  surface water,
sediments, and air.  The RI identified the nature and extent of contamination at the site, and included
performance of the BLRA.  Based on the BLRA, it was concluded that unacceptable risks may have existed to
people working at the site, primarily from dermal contact of constituents in site soils.

    The purpose of the Removal Action was to remove contaminated soils from the PSF site,  thereby
preventing current or future exposure to site workers.  By removing soils causing excessive cumulative
risk from the site, long-term protectiveness is provided under the future anticipated land use scenario.
Therefore, no further remedial action is warranted for surface and subsurface soils.

    The groundwater does not pose a risk to human health or the environment.  No pesticides have been
detected during groundwater monitoring.  Concentrations of inorganics in the groundwater were
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statistically similar to background concentrations, or occurred below Federal Maximum Contaminant Levels
(MCLs) for drinking water.  In addition, no complete exposure pathway currently exists, and the potential
for use of the groundwater as a potable water supply in the future is remote.  Therefore, remedial action
is not warranted for groundwater.

    Likewise, constituent concentrations detected in site sediments, surface waters, and air do not pose
unacceptable risk to human health or the environment under current and future planned land use scenarios.
Therefore, remedial action is not warranted for these media.

2.5 SUMMARY OF SITE CHARACTERISTICS

    Initial RI activities began in 1990, with field activities occurring in 1992 and 1993.  A
non-time-critical Removal Action addressing contaminated soils was performed in 1994.  This section will
discuss characteristics of the site by media, including the soils, groundwater, surface water, and
sediments.  A comparison of the extent of contamination in the soils prior to and following the Removal
Action is presented.

2.5.1 Surface and Subsurface Soils

Pre-Removal Soil Characteristics

    Soils were sampled during the initial RI field activities in 1992 and 1993.  Surface and shallow
subsurface soil samples were collected and analyzed to assess the extent of soil contamination.  The
primary constituents found in soils at the site consisted of arsenic, the pesticide DDT and related
compounds DDE and ODD, chlordane, dieldrin, and heptachlor.  Other inorganics  (such as barium, chromium,
and lead) and organics (such as polynuclear aromatic hydrocarbons [PAHs])  were also detected.  Additional
soil samples were collected prior to the soil Removal Action to further define the extent of
contamination at the site.

    Areas of pesticide-contaminated soil are identified based on sample results from both the RI field
activities and the removal action sampling activities.  The areas are located adjacent to and east of
Building 348  (Figure 2-3).  Table 2-1 summarizes the analytical data for pesticides occurring in the
soils prior to excavation activities.  Exceedances of the Removal Action Goals were observed for several
of the pesticide constituents in both surface and subsurface soils.

    In the surface soils, the Removal Action Goals were exceeded by chlordane in 12 samples, dieldrin in
5 samples, heptachlor in 1 sample, and DDT and metabolites in 4 samples.  Maximum concentrations of
chlordane, DDT and DDT metabolites occurred within the same order of magnitude as the Removal Action
Goals.  The detected maximum concentrations of dieldrin and heptachlor were an order of magnitude greater
than the Removal Action Goals.

    Of the subsurface soil samples, chlordane exceeded Removal Action Goals in 18 samples, dieldrin in 1
sample, heptachlor in 3 samples, and DDT in 10 samples.  With the exception of DDT and heptachlor,
maximum concentrations of the pesticides were within the same order of magnitude as their respective
Removal Action Goals.  The maximum detected DDT and heptachlor concentrations were an order of magnitude
greater than the Removal Action Goal.

    Inorganic constituents were routinely found in detectable concentrations in both background samples,
with a maximum of 770 mg/kg at the 2- to 2.5-foot depth interval.  Arsenic concentrations occurred above
background levels in two samples with a maximum of 120 mg/kg at the 3.5- to 4.5-foot depth interval.

    Several PAHs were detected in a single surface soil sample and a small number of subsurface soil
samples.  PAHs were detected in the soils in three areas of the PSF:  1) along the fence to the east of
the PSF and extending east; 2) at the bottom of the culvert leading to the east from the southeastern
corner of the fence; and 3) near the southeastern corner of the PSF.  The sources of PAHs are believed to
be the result of runoff from paved areas and pressure-treated lumber.  PAHs represented a small fraction
of the cumulative risk presented by the site soils and were not considered contaminants of concern.

    In the Removal Action, approximately 2,700 tons of soil were excavated and disposed of in an approved
landfill off-site.  Excavation of soil was completed in phases, with each phase followed by confirmatory
soil sampling.  The confirmatory soil sampling data were used to plan excavations for the subseguent
phases.  The areas and depth of excavation are presented on Figure 2-4.
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Post-Removal Soil Characteristics

    The site characteristics for the soil media were significantly altered by the Removal Action.  The
contaminated soils which contributed to the unacceptable risks to site workers were largely removed by
the action, with only a few isolated locations remaining with soils exceeding Removal Action Goals.  This
is the case for both surface and subsurface soils.  Analytical data for the pesticides in samples
collected following the Removal Action are summarized in Table 2-1.  Figure 2-5 shows the locations of
surface and subsurface samples exceeding Removal Action Goals for residual pesticides in the soils.
Following the Removal Action, chlordane, heptachlor, DDT, and DDT metabolite levels in surface soil
samples did not exceed the Removal Action Goals.  Dieldrin slightly exceeded the Removal Action Goal in a
single surface sample. Maximum detection concentrations for all pesticides had been reduced in the
surface soils.

    Nine chlordane samples, one DDT sample, and two heptachlor samples exceeded the Removal Action Goals
in subsurface soils.  Some of the subsurface samples exhibiting exceedances were located adjacent to the
building foundation, where excavation activities could potentially have endangered the building
stability.  The maximum detected concentrations for chlordane and heptachlor were an order of magnitude
greater than the Removal Action Goal.  The maximum DDT concentration was only slightly above the Removal
Action Goal.  With the exception of chlordane and heptachlor, detected maximum concentrations of the
pesticides had been reduced by at least an order of magnitude.

    Of the inorganics, lead was found to occur at elevated concentrations at two locations, with a
maximum concentration of 770 mg/kg at the 2.0- to 2.5-foot soil depth.  Isolated occurrences of elevated
arsenic concentrations were encountered, with concentrations exceeding the Removal Action Goal (7.1
mg/kg) in 3 samples.  However, 2 samples collected under the asphalt pavement exhibited concentrations of
16 mg/kg and 20 mg/kg.  The third sample, collected from a location east of Building 348 at a depth of 5
feet, was a minor exceedance at 9.4 mg/kg.

    PAHs were not analyzed during the Removal Action.  Based on the locations of the PAH-contaminated
soils prior to the Removal Action, these soils have mostly been excavated (as described above) and
replaced with clean fill.

2.5.2 Groundwater

    Groundwater samples were collected from monitoring wells installed at the site to evaluate the
possibility of contamination leaching from the soil into the groundwater.  Well locations are shown on
Figure 2-2.  Groundwater samples were analyzed for volatile and semi-volatile organics, pesticides/PCBs,
metals, organophosphorus pesticides, herbicides, chloride, sulfate, nitrate, and bicarbonate.  The
groundwater sampling results indicated the presence of several inorganic constituents.  However,  the
concentrations of these compounds detected in samples collected from the on-site monitoring wells were
statistically similar to the concentrations found in samples collected from background monitoring wells
with the exception of beryllium in a single on-site well.  No pesticides were detected.  A single
detection of toluene was observed.

2.5.3 Surface Water and Sediments

    The possibility of contaminant migration from surface run-off was assessed by analyzing surface-water
and sediment samples from a nearby drainage feature east and southeast of the site.  Constituents
detected in upgradient and downgradient surface water consisted of various metals and inorganics that are
naturally occurring in the area.  Downgradient concentrations were consistent with the upgradient sample
except that aluminum, iron, vanadium, zinc, and sulfate were slightly above background in some samples.
Sediment analytical results revealed that volatile organic compounds, pesticides, PAHs, and metals
existed within the drainage ditch downgradient and to the east of the PSF site.

2.6 SUMMARY OF SITE RISKS

    Two risk assessments have been conducted for the PSF site at Fort Riley.  The first of these was a
BLRA, which was presented in the RI report.  Based on the results of the RI and the BLRA, a
non-time-critical Removal Action took place.  The remedial action objectives for the Removal Action were
human health risk-based concentrations.  Following the Removal Action, a residual risk assessment  (RRA)
for human health was conducted using data from areas that were not excavated and from confirmation
sampling during the Removal Action.  Both the BLRA and RRA were performed in a manner consistent with the
USEPA "Risk Assessment Guidance for, Superfund" for human health and ecological risk assessments.
Summaries of the BLRA and RRA are presented in Sections 2.6.1 and 2.6.2, respectively.  In addition, a
summary of the effectiveness of the Removal Action is presented in Section 2.6.3.  Finally, a summary of
the ecological risk assessment activities is presented in Section 2.6.4.
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2.6.1 Baseline Risk Assessment

    A summary of the results of the BLRA are presented in this section.   The results of the BLRA
indicated that unacceptable risks due to potential exposures to both carcinogenic and noncarcinogenic
constituents existed at the PSF site.  The risk estimates presented in the BLRA included potential
ingestion, inhalation,  and dermal contact exposures to surface soil, subsurface soil, surface water,  and
sediment.  These risks were the basis for implementing the non-time-critical Removal Action.  The
chemicals of concern (COCs) that were primarily responsible for the risks calculated for the BLRA were:

       •       Surface Soil:  arsenic,  barium,  benzo(a)anthracene,  chlordane,  chromium,  DDT,  DDE,  ODD,
              dieldrin,  heptachlor
       •       Subsurface Soil:   arsenic,  benzo(a)pyrene,  chlordane,  DDT,  DDE,  ODD,  dieldrin
       •       Surface Water:   arsenic
       •       Sediment:   arsenic

Objectives and Methodology

    The objective of the BLRA was to determine the effects of the existing conditions on the exposed and
potentially exposed populations if no action were to be taken to remediate conditions at the site.  The
results of the BLRA were used to determine whether further study and/or remedial actions were necessary.

    The BLRA consisted of four successive steps which are discussed in the following sections:

       •       Identification of Chemicals of Concern
       •       Exposure  Assessment
       •       Toxicity  Assessment
       •       Risk Characterization

    Subpopulations of Potential Concern - Sensitive subpopulations  (i.e., nurseries, nursing homes,  or
hospitals) present within a three-mile radius of the PSF site include Irwin Army Community Hospital.
Children, the elderly,  and women of child-bearing age living nearby were considered sensitive
subpopulations.  Women of child-bearing age and children were known to be living in Main Post Family
Housing Area No. 5, located approximately 0.3 miles northwest of PSF. Children were evaluated as a
sensitive subpopulation for the current sediment/surface-water recreational scenario and future
residential pathways considered in the BLRA.

    Current Land Use - At the time the BLRA was being conducted, the PSF and DEH yard were being used as
a storage and maintenance area supporting the services necessary to maintain the buildings, grounds,  and
utilities systems at Fort Riley.  Building 348 was being used to store herbicides,  preformulated
pesticides, general improvement materials, and paint.  Several subsurface utility lines were located
adjacent to and beneath the site.  The site and surrounding area are within a zone designated for
Industrial land use in the Fort Riley Master Plan.

    Potential Future Land Uses - In developing future use scenarios, it was assumed that no remedial
actions were to take place.  Such "no-action" scenarios also provided a baseline for the comparison of
remedial alternatives in the Feasibility Study.  Future use scenarios assumed that future development of
the site will be unrestricted.  According to 1992 and 1993 interviews with Fort Riley's DEH Master
Planner and personnel from Fort Riley's Real Property Section, the future use of the PSF and the
surrounding land was considered unlikely to change from its use as an eguipment storage area as long as
Fort Riley remained an active military installation.  Fort Riley was not being considered for placement
on the military installation closure lists.  Residential development of the site at some future date was
considered unlikely because the elevation of the PSF is only approximately 10 to 15 feet above the Kansas
River floodplain, and the land is not protected by a levee.  The site and surrounding area are within a
zone designated for Industrial land use in the Fort Riley Master Plan.  Future land use is expected be
industrial.

    The potential exposure pathways that were guantified in the BLRA are summarized in Table 2-3.

    Toxicity Assessment - A toxicity assessment is an integral part of the risk assessment in which
guantitative reference values describing the COCs are evaluated.  For the BLRA, this effort was conducted
using the following hierarchy of sources of toxicity information,  as suggested by USEPA guidance:
-------
              USEPA Integrated Risk Information System (IRIS)
              USEPA Health Effects Assessment Summary Tables  (HEAST)
       •       USEPA Environmental Criteria and Assessment Office (ECAO)  (currently the National  Center for
              Environmental Assessment [NCEA]
              USEPA Criteria Documents

    The reference doses (RfDs) and reference concentrations (RfCs)  for noncarcinogenic COCs and cancer
slope factors (CSFs) for carcinogenic COCs that were used in the RRA are presented on Table 2-4 and Table
2-5, respectively.  By definition, the RfD and RfC values are an estimate of a daily exposure level for
the human population that is likely to be without appreciable risk of deleterious effects during a
lifetime.  For carcinogenic chemicals, the CSF correlates the estimated total chronic day intake of a
chemical to a probability for incremental cancer risk.

    Toxicity information for the dermal exposure route is typically not available.  Therefore,  in
accordance with USEPA Region VII guidance, oral RfDs and cancer slope factors were used directly as
dermal toxicity values.

Risk Characterization

    The risk characterization integrates the results of the exposure and toxicity assessments into
guantitative and gualitative expressions of risk.  To characterize potential noncarcinogenic effects,
comparisons are made between the estimated chemical intakes and the RfDs and/or RfCs for those chemicals.
To characterize potential carcinogenic effects, estimated chemical intakes are multiplied by the
chemical-specific CSFs.

    Noncarcinogenic Effects Characterization - Noncarcinogenic effects were characterized by comparing
the estimated chemical intakes to the appropriate RfD and/or RfC value.  When the estimated chronic daily
intake of a chemical exceeds the appropriate RfD, there may be a concern for potential noncancer effects
from exposure to that chemical.  The ratio of the chronic daily intake to the chronic RfD and/or RfC is
referred to as the "hazard guotient (HQ)."  The sum of the hazard guotients for each chemical in a
specific pathway is termed the "hazard index  (HI)."  It is important to note that the HQ does not
represent a statistical probability; a ratio of 0.01 does not mean that there is a one in one hundred
chance of the effect occurring.  Rather, an HQ guotient greater than 1 indicates that the "threshold" for
that chemical has been exceeded.

    Carcinogenic Risk Characterization - Risks from potential carcinogens were estimated as probabilities
of excess cancers as a result of exposure to chemicals from the site.  The CSF correlates estimated total
chronic daily intake directly to incremental cancer risk.  Chemical-specific cancer risks were estimated
by multiplying the CSF by the chronic daily intake estimates;  pathway-specific cancer risks were
estimated by summing the chemical-specific risks for the particular pathway.  The results of the risk
characterization are considered as upper-bound estimates of the potential carcinogenic risk.

Summary of the Baseline Risk Assessment

    As presented and discussed in this section, the results of the BLRA indicated that unacceptable risks
existed at the PSF due to the site-specific constituents.  The His and cancer risks calculated during the
BLRA are summarized below.  These risk estimates were the basis for the Removal Action at the PSF.

                            Summary of Baseline Risk Assessment (BLRA) Results

    Receptors                       Total Hazard Index         Total Cancer Risk

    Current:
    Site Worker                              9                      8 x 10 -4
    Landscaper                             0.03                     2 x 10 -6
    Utility Worker                         0.06                     7 x 10 -6
    Recreational Child                     2.2

    Future:
    Site Worker                              33                      4 x 10 -3
    Landscaper                             0.23                      1 x 10 -5
    Utility Worker                         0.22                      2 x 10 -5
    Construction Worker                      24                      1 X 10 -4

    Recreational Child                      2.2
-------
2.6.2 Residual Risk Assessment

    The RRA provided a conservative indication of the potential risks due to exposure to site-specific
chemicals remaining at the PSF site.  For soil/sediment, none of the exposure pathways for which risks
were assessed in the RRA exceeded a hazard index of 1.  Similarly, no exposure pathway exceeded a cancer
risk of 1 x 10 -6, although it should be noted that cancer risk estimates for two pathways were
approximately eguivalent to 1 x 10 -6.  These were potential dermal exposure to surface soil by current
and future site workers.  However, because the potential risks at the site resulting from exposure to
site-related constituents were estimated  (using conservative assumptions) to be less than or egual to the
most conservative point-of-departure applied to risk assessments for carcinogenic constituents, risks at
the site were considered to be acceptable.

Objectives and Methodology

    Following completion of the Removal Action, the RRA was conducted to address the human health risks
that remained at the site.  In order to focus the RRA, residual risks were only calculated for exposure
pathways for which cancer risks were estimated to be egual to or greater than 1 x 10 -6 (for carcinogens)
or those for which hazard indices were estimated to be egual to or greater than 1 (for non-carcinogens)
in the BLRA.  That is, those pathways for which the numerical risk or hazard values would not be
significant in the total risk or hazard index value were not re-calculated.  The exposure pathways for
which residual risks were evaluated are    shown on Table 2-6.  The other primary differences between the
BLRA and RRA were:

       •      Revised exposure point concentrations (due to the Removal Action)
       •      Revised dermal absorption factors

Chemicals of Concern

    For the RRA, the chemicals remaining in the soil/sediment at the site following the Removal Action
were retained as COCs.  The data that were used were from the analyses performed as part of the Removal
Action and, where appropriate, from the RI (i.e., data for locations not  excavated during the Removal
Action).  Areas that were excavated to a depth of 2 feet or more during the Removal Action, and then
backfilled, were considered subsurface soil.   Other areas  (i.e., areas not excavated or those excavated
to a depth of less than 2 feet) were considered to be surface soil unless covered by pavement or
concrete.

Exposure Assessment

    The PSF site was inactive when the RRA was conducted.  Pesticides and related materials are now
stored in the new pesticide building located approximately 1,500 feet from the site.  Future land use is
expected to be very similar to the current and historical uses.  The site and surrounding area are within
a zone identified in the Fort Riley Master Plan as Industrial.  The area is expected to remain classified
as Industrial in the future.  The portion of the Building 348 structure used for pesticide and herbicide
storage will be examined and "closed" as appropriate.  This action may or may not involve demolition of
the structure and/or its floor slab and foundation.  The demolition of Building 348 and new construction
is also a future possibility.

    The exposure assessment for the RRA was conducted in the same manner as the BLRA, except for the two
differences noted previously.  First, exposure point concentrations were recalculated using data from
site conditions after the Removal Action.  Second, dermal absorption factors were revised  (downward from
100 percent) on the basis of information in ATSDR's Toxicity Profiles.  The dermal absorption factors
used in the RRA are shown below.

    Dermal Absorption Factors Used in the Residual Risk Assessment (RRA)

    Parameter                       Revised Dermal Absorption       Source
                                    Factor
    Inorganic Compounds             0.01  (1 percent)                 USEPA
    Volatile and Semi-Volatile      1  (100 percent)                 Conservative assumption
     Organic Compounds
    Chlordane                       0. 109 (10.9 percent)           ATSDR
    Heptachlor                      0. 109 (10.0 percent)           ASTDR
    DDD, DDE, and DDT               0.378 (37.8 percent)            USEPA
-------
Toxicitv Assessment

    For the RRA, the toxicity assessment was conducted as described in Section 2.6.1 for the BLRA.  In
addition, the toxicity values used in the BLRA were verified to be current for use in the RRA.

Risk Characterization

    As discussed in Section 2.6.1, the risk characterization portion of a risk assessment integrates the
results of the exposure and toxicity assessments into quantitative and qualitative expressions of risk.
To characterize potential noncarcinoqenic risks, the estimated chemical intakes are compared to (i.e.,
divided by) the chemical-specific RfDs and RfCs for the COCs.  To characterize potential carcinoqenic
risks, the estimated chemical intakes are multiplied by the chemical-specific slope factors for the COCs.
The results of the risk characterization, as calculated and provided in the RRA,  are presented below.

    For noncarcinoqens, none of the exposure pathways evaluated had an HI estimate qreater than l,the
standard point-of-departure below which adverse noncarcinoqenic health effects are not expected.  A
summary of these HI estimates,  by pathway, is presented in Table 2-7.

    For carcinoqens, none of the exposure pathways evaluated had a risk qreater than 1 x 10 -6 , the most
conservative point-of-departure typically used to evaluate unacceptable cancer risk.  A summary of the
cancer risk estimates, by pathway, is presented in Table 2-8.

2.6.3 Effectiveness of the Removal Action

    The non-time-critical Removal Action at the PSF reduced the risks associated with site-related
contamination to acceptable levels for current and reasonably anticipated future land use and exposures.
The Removal Action was undertaken on the basis of unacceptable risks presented in the BLRA due primarily
to dermal exposures to contaminated soil at the site.  The results of the Post-Removal Action risk
assessment (i.e., the RRA) indicated that the risks due to potential exposures at the PSF were
acceptable.  The results of the RRA indicated that the Removal Action was effective in reducinq the
site-related risks at the PSF site.

2.6.4 Ecological Risk Assessment

    The ecoloqical risk assessment (ERA) that was conducted durinq the RI was re-evaluated as part of the
RRA.  For the ERA, potential receptors present in the vicinity of the PSF and the potential pathways by
which these receptors miqht be exposed to the COCs present in surface soil, surface water, and sediment
were identified.  Possible risks to environmental receptors arisinq from exposure to site contaminants
were characterized.  The objectives of the ERA were to:

       •       Evaluate the value or uses of nearby natural resources (e.g.,  land,  air,  water,  biota)
       •       Identify potential environmental impacts
       •       Assess the significance of identified environmental impacts

The ERA comprised the followinq tasks:

Ecological Receptor Identification

       •       Exposure Pathway  Evaluation
       •       Selection of Relevant Exposures
       •       Toxicity Assessment and Identification of ARARs
       •       Risk Characterization

    Adverse impacts to ecoloqical receptors were not expected due to the developed nature of the site and
surroundinq area, and the limited amount of release to media that would support receptors.  In summary,
neqative impacts to fauna and flora at the PSF site were not readily apparent durinq the site
characterization phase of the RI.  Althouqh terrestrial and aquatic life in the area of the drainaqe
ditch may potentially suffer adverse effects from constituents detected in site surface-water and
sediment samples, other (larqer) sources of surface water/sediment are located nearby.  Ecoloqical
receptors would tend to favor these sources over the intermittent stream on site.  Therefore, the
environmental impact of the contamination detected in the surface water and sediment was considered to be
low.  In addition, the contamination present in site surface water and sediment was not expected to
impact downstream media because the natural character of the drainaqe ditch (i.e., its intermittent flow)
does not consistently discharqe surface water and flush sediments to downstream points.
-------
    Similarly, potential risks to environmental receptors due to exposure to soil at the site were
considered to be minimal.  The area most impacted by soil contamination prior to the Removal Action (the
small stressed area of vegetation noted in the RI report) was of very limited extent(approximately 20
feet by 20 feet) .   This area of stressed vegetation was excavated during the Removal Action.  There are
areas adjacent to the site that provide suitable habitats and food supplies for animal species that may
pass by or freguent the site.

2.7  SUMMARY DESCRIPTION OF THE "NO FURTHER ACTION" ALTERNATIVE

    The selected remedy for the Pesticide Storage Facility, Operable Unit 002,  at Fort Riley is No
Further Action.  A Removal Action in which contaminated soils were excavated, transported,  and disposed
off-site was completed in 1994.  Based upon current and projected land use at the site and the
populations that may be exposed to site contamination,  it has been determined that the site does not pose
a significant threat to public health, welfare, and the environment.

Basis of "No Further Action" Alternative:

•      Current and anticipated reasonable future land use is industrial.   Future residential or other
       land uses resulting in higher exposure levels is not anticipated.
•      No contamination of groundwater and no current or anticipated future use of groundwater beneath
       the site.

    The previous release of contamination at the site will be annotated in the Master Plan Environmental
Overly  (MPEO) from which users of the Master Plan will be directed to the documents that detail the
results of associated investigations and the remedial actions taken.

    If a significant change in land use at the PSF is proposed by Fort Riley, or if any portion of the
site property is transferred or leased to a non-government entity, Fort Riley will notify Region VII of
the U.S. Environmental Protection Agency (EPA) and the Kansas Department of Health and Environment  (KDHE)
in writing of the proposed change in land use or transfer of lease of the property or a portion of the
property.  If the change in land use is determined to be a major change in land use, a reevaluation of
the remedy decision will be reguired.  Depending upon the nature of the transfer or lease of the site
property, EPA and/or KDHE may reguire Fort Riley to reconsider the no further action decision selected in
this Records of Decision, which may reguire the implementation of additional response actions, including
institutional controls, prior to the transfer or lease of site property.   A major land use change is a
change in land use classification that is inconsistent with the exposure assumptions presented in the
risk assessment and which may reasonably be expected to result in unacceptable risk.

    At this time,  no further remedial action is necessary for Operable Unit 002, the Pesticide Storage
Facility to ensure protection of human health and the environment.  Section 300.430(f) (4) (ii) of the
National Oil and Hazardous Substances Pollution Contingency Plan  (NCP) states that if a remedial action
is selected that results in hazardous substances, pollutants or contaminants remaining at a site above
levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action
no less often than every five years after initiation of the selected remedial action.   Although the
decision reached in the Record of Decision is no further action, this decision is based upon current and
reasonably projected land use and exposures.  However,  hazardous substances, pollutants or contaminants
may remain at the site above levels that would allow for unlimited use and unrestricted exposure.
Therefore, the five year review will apply to this site.

3.0 RESPONSIVENESS SUMMARY

    No verbal or written comments were received regarding the Pesticide Storage Facility, Ft. Riley
Proposed Plan at a public Availability Session held on September 4, 1997, or during the 30-day public
comment period.  Therefore, a responsiveness summary is not included.
-------
                                        FIGURES





-------
                      TABLE 2-1

  COMPARISON OF PKE-KEMOVAL AND POST-REMOVAL ACTION
POSITIVE ANALYTICAL RESULTS WITH REMOVAL ACTION GOALS
                  Record of Decision
              Pesticide  Storage Facility
                  Fort Riley,  Kansas




Constituent

Chlordane
DDD
DDE
DDT
Dieldrin
Heptachlor


Removal
Action Goal
Surface Soils
(mg/kg)
1.58
1.73
1.73
1.73
0.127
0.05


Frequency
of
Detection

56/102
16/38
19/26
74/102
40/102
15/102
SURFACE SOILS
Pre-Removal
Minimum
Detected
Concentration
(mg/kg)
0.021
0.022
0.036
0.006
0.007
0.001
SURFACE SOILS
Post-Removal
Maximum
Detected
Concentration
(mg/kg)
5.89
0.925
1.8
2.63
1.4
0.129
Frequency
of
Detection

17/52
7/18
12/18
35/52
20/52
2/52
Minimum
Detected
Concentration
(mg/kg)
0.0207
0.0237
0.0356
0.012
0.007
0.004
Maximum
Detected
Concentration
(mg/kg)
1.12
0.454
0.847
1.29
0.158
0.0093




Constituent

Chlordane
DDD
DDE
DDT
Dieldrin
Heptachlor


Removal
Action Goal
Surface Soils
(mg/kg)
1.58
1.73
1.73
1.73
0.127
0.05


Frequency
of
Detection

89/189
37/155
68/155
94/189
18/199
18/189
SURFACE SOILS
Pre-Removal
Minimum
Detected
Concentration
(mg/kg)
0.005
0.001
0.008
0.011
0.004
0.001
SURFACE SOILS
Post-Removal
Maximum
Detected
Concentration
(mg/kg)
8.71
1.34
1.16
33
0.2
0.3
Frequency
of
Detection

46/133
20/106
35/106
47/133
12/133
9/133
Minimum
Detected
Concentration
(mg/kg)
0.0051
0.0013
0.0104
0.011
0.007
0.0012
Maximum
Detected
Concentration
(mg/kg)
10.2
0.925
0.794
1.95
0.077
0.3
-------
                                                                        TABLE 2-2

                                                   SUMMARY  OF CHEMICALS OF CONCERN FOR  THE BLRA
                                                                  Record of  Decision
                                                              Pesticide Storage Facility
                                                                  Fort Riley,  Kansas

                                                             Range of Detected Concentrations
Aluminum
Anthracene
Arsenic
Barium
Benzo (a)anthracene
Benzo[a]pyrene
Benzo(b)fluoroanthene
Benzo(k)fluoroanthene
Beryllium
Cadmium
alpha-Chiordane
gamma-Chiordane
Chromium
Chrysene
Copper
4.4'-DDT
Dibenzofuran
Dieldrin
Indeno[1,2,3-cd]pyrene
Lead
Manganese
Mercury
Phenanthrene
Vanadium
Chloride, inorganic
Nitrate
Sulfate
Bicarbonate, as CaCO 3
Surface
Soils
(mg/kg)
NT
ND
2.4-16
35-130
: 0.12-0.16
ND
ND
ND
NT
ND
0.029-1 . 6
0.03-1.6
6. 9-156
< 0.12-0.45
NT
0.45- 1*
ND
0.077-0.094
ND
32-540
NT
ND
< 0.16-0.78
NT
NT
NT
NT
NT
Subsurface
Soils
(mg/kg)
NT
0.25-0.76
0.8-120
39-160*
0.11-1.8
0.27-1.3
0.38-1.4
0.46-1.2
NT
0.7-5
0.0037-1 .5
0.004-1 .6
4 .5-41
0.11-1.7
NT
0.012-33
0.055-0.13
0.01-0.2*
0.175-0.38
4 .4-770
NT
0.1-1.3
0.23-2.7
NT
NT
NT
NT
NT
Monitoring WCU
Soil Borings
(mg/kg)
NT
ND
0.4-3.7
44-190
0.11-0.6
< 0.11- 0. 68
< 0.36-1
ND
NT
ND
0.015-0.073
0.0051-0.071
4 .8-20
0.11-0.64
NT
ND
ND
0.0087-0.013
< 0.36-0.48
4 .7-58
NT
0.1-0.3
< 0.14-0.56
NT
NT
NT
NT
NT
Surface
Water
(mg/L)
0.6-12 B
ND
0 . 004-0 .0044
0.014-0.29
ND
ND
ND
ND
ND
< 0.004-0.0045
ND
ND
0.01-0.024
ND
0.0064-0.013
ND
ND
ND
ND
< 0. 002-0. 0042M
0.063-0.19
ND
ND
0.0064-0.026
38-65
NT
74-106
170-290

Sediment
(mg/kg)
NT
ND
0.8-3.8
44-150







0.12-0.16
ND
ND
ND
NT
1.3-3.3
0.0058-0.
0.0076-0.
4 .2-25
0.12-0.
NT
0 . 0086-0
ND
0.02-0.
ND
15-210
NT
0.1-0
0.2-0
NT
NT
NT
NT
NT





067
065

24

.48

056



.4
.36





ND - Not detected
NT - Not tested
B - Associated with blank  contamination
M - Matrix interference
* Not selected as a chemical  of potential concern in this medium
-------
                                                              TAKLE 2-3
Medium
Surface Soils
Land Use/Populations

Current Land Use:

Landscapers



Utility Workers



Site Workers
                     Recreational/Trespassing Child



                     Future Land Use:

                     Landscapers



                     Utility Workers



                     Site Workers



                     Construction Worker



                     Recreational/Trespassing Child
EXPOSURE PATHWAY SUMMARY FOR THE BIiRA
          Record  of  Decision
      Pesticide Storage  Facility
          Fort Riley,  Kansas

          Exposure  Pathway
          Incidental Ingestion,
          Inhalation of Fugitive Dust,
          Dermal Contact

          Incidental Ingestion,
          Inhalation of Fugitive Dust,
          Dermal Contact

          Incidental Ingestion,
          Inhalation of Fugitive Dust,
          Dermal Contact

          Incidental Ingestion,
          Inhalation of Fugitive Dust,
          Dermal Contact
                                     Incidental Ingestion,
                                     Inhalation of Fugitive Dust,
                                     Dermal Contact

                                     Incidental Ingestion,
                                     Inhalation of Fugitive Dust,
                                     Dermal Contact

                                     Incidental Ingestion,
                                     Inhalation of Fugitive Dust,
                                     Dermal Contact

                                     Incidental Ingestion,
                                     Inhalation of Fugitive Dust,
                                     Dermal Contact

                                     Incidental Ingestion,
                                     Inhalation of Fugitive Dust,
                                     Dermal Contact
-------
                     Current Land Use:

Subsurface Soils     Utility Workers                      Incidental Ingestion,
                                                          Inhalation of Fugitive Dust,
                                                          Dermal Contact

                     Landscapers                          Incidental Ingestion,
                                                          Inhalation of Fugitive Dust,
                                                          Dermal Contact

                     Recreational/Trespassing Child       Incidental Ingestion,
                                                          Inhalation of Fugitive Dust,
                                                          Dermal Contact
-------
Medium
Subsurface Soils
Sediments
Surface Water
Land Use/Populations

Future Land Use:

Utility Workers



 Landscapers



 Construction Worker
            TABLE 2-3
EXPOSURE PATHWAY SUMMARY FOR THE BLRA
          Record  of  Decision
      Pesticide Storage  Facility
          Fort Riley,  Kansas

        Exposure Pathway
        Incidental Ingestion,
        Inhalation of Fugitive Dust,
        Dermal Contact

        Incidental Ingestion,
        Inhalation of Fugitive Dust,
        Dermal Contact

        Incidental Ingestion,
        Inhalation of Fugitive Dust,
        Dermal Contact
                        Recreational/Trespassing Child  Incidental Ingestion,
                                                        Inhalation of Fugitive Dust,
                                                        Dermal Contact
                        Current Land Use:
 Site Workers
                                                        Dermal Contact,
                                                        Incidental Ingestion
                        Recreational/Trespassing Child  Dermal Contact,
                                                        Incidental Ingestion
                        Future Land Use:
                        Site Workers
                                                        Dermal Contact,
                                                        Incidental Ingestion
 Recreational/Trespassing Child  Dermal Contact,
                                 Incidental Ingestion

 Current Land Use:

 Site Workers                     Dermal Contact

 Recreational Trespassing Child   Dermal Contact

 Future Land Use:

 Site Workers                     Dermal Contact

 Recreational/Trespassing Child   Dermal Contact
-------
                                                                  TAKLE 2-4
                                                    TOXICITY VALUES FOR NONCARCINOGENIC EFFECTS
                                                             Record of Decision
                                                         Pesticide Storage  Facility
                                                             Fort Riley, Kansas
Parameter
Oral-Route
Chlordane
4,4'-DDD
4,4' -DDE
4,4' -DDT
Dieldrin
Heptachlor
Benzene
Methylene chloride
Toluene
Benzo[a]anthracene
bis (2-Ethylhexyl)phthalate
Chrysene
Diethylphthalate
Fluoranthene
Phenanthrene
Pyrene
Aluminum
Arsenic
Barium
Beryllium
Cadmium

Chromium
Lead
Manganese

Mercury
Selenium
Silver
Thallium
Vanadium
Nitrate
Chronic RfD
(mg/kg-day)
6.0E-05
no data
no data
5.0E-04
5.0E-05
5.0E-04
no data
6.0E-02
2.0E-01
no data
2.0E-02
no data
8.0E-01
4.0E-02
no data
3.0E-02
2.9E+00
Confidence
Level (a)
low


medium
medium
low

medium
medium

medium

low
low

low

3.0E-04                medium
7.0E-02                medium
5.0E-03                low
l.OE-03 (food)         high
5.0E-04 (water)
5.0E-03                low
no data
1.4E-01 (food)
5.0E-03 (water)
pending   (3.0E-04)
5.0E-03                 high
withdrawn (5.0E-03)     low
7.0E-05                 low
9.0E-03                 low
1.6E+00                 high
                                            Uncertainty
                                          Critical Effect

                                        Regional liver hypertrophy in females
       Liver lesions
       Liver lesions
       Liver weight increases

       Histological alterations of the liver
       Changes in liver and kidney weights

       Increased relative liver weights

       Altered organ weights
       Liver weight increases

       Kidney effects

Hyperpigmentation,  keratosis, vascular complications
       Increased blood pressure
       No adverse effects
       Significant proteinuria

       No effects reported

       Central nervous system effects

       Kidney effects
       Clinical selenosis
       Argyria
       Increased levels of SGOT & LDH
       Decreased hair cystine
       Methemoglobinemia
Factor (b)
1000


100
100
300
100
1000

1000

1000
3000

3000

is 3
3
100
10
500

1
1000
3
3
3000
100
1
Sour<
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
EPA
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
HE AST
IRIS
IRIS
IRIS
IRIS
IRIS
-------
                                               TABIiE 2-5
                          TOXICITY VALUES FOR POTENTIAL CARCINOGENIC EFFECTS
                                             Record of Decision
                                          Pesticide Storage Facility
                                              Fort Riley, Kansas
Parameter

Oral Route
Chlordane
4,4'-DDD
4,4'-DDE
4,4'-DDT
Dieldrin
Heptachlor
Benzene
Methylene chloride
Toluene
Benzo[a]anthracene
bis (2-Ethylhexyl)phthalate
Chrysene
Diethylphthalate
Fluoranthene
Phenanthrene
Pyrene
Aluminum(b)
Arsenic
Barium
Beryllium
Cadmium
Chromium(c)
Lead
Manganese
Mercury
Selenium
Silver
Thallium
Vanadium
 Cancer  Slope  Factor(a)
(kg-day/mg)
Weight of Evidence
Classification(d)
      Type of Cancer
   1.3E+00
   2.4E-01
   3.4E-01
   3.4E-01
   1.6E+01
   4.5E+00
   2.9E-02
   7.5E-03
   no  data
   1.1E+00*
   1.4E-02
   2.9E-02*
    no data
    no data
    no data
    no data
    no data
    1.8E+00
    no data
    4.3E+00
    no data
    no data
    no data
    no data
    no data
    no data
    no data
    no data
    no data
         B2
         B2
         B2
         B2
         B2
         B2
          A
         B2

         B2
         B2
         B2
          A

          B2


          B2
Liver tumors
Lung, liver, and thyroid tumors in rodents
Liver tumors, liver cancer, and thyroid tumors
Liver tumors
Liver cancer
Liver tumors
Increased incidence of nonlymphocytic leukemia
Increased incidence of hepatocellular neoplasms

    Tumors in mice via various routes
    Increases in liver tumor responses
    Malignant lymphoma, skin cancers, in mice
    Skin cancer

    Lung cancer in rats/monkeys via inhalation


    Renal tumors, affects gene expression
                                                                                                                                  Source
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
EPA(a)
EPA(a)
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
-------
                                                                  TABLE 2-5
                                             TOXICITY VALUES FOR POTENTIAL CARCINOGENIC EFFECTS
                                                             Record of Decision
                                                         Pesticide Storage Facility
                                                             Fort Riley, Kansas
Parameter

Chlordane
4,4' -DDD
4.4'-DDE
4,4'-DDT
Dieldrin
Heptachlor
Benzene
Methylene chloride
Toluene
Benzo[a]anthracene
bis (2-Ethylhexyl)phthalate
Chrysene
Diethylphthalate
Fluoranthene
Phenanthrene
Pyrene
Aluminum(b)
Arsenic
Barium
Beryllium
Cadmium
Chromium(c)
Lead
Manganese
Mercury
Selenium
Silver
Thallium
Vanadium
Nitrate
Cancer Slope Factor(a)
(kg-day/mg)

   1.3+00
  no data
  no data
   3.4-01
  1.6E+01
  4.6E+00
  2.9E-02
  1.6E-03
  no data
  no data
  no data
  no data
  no data
  no data
  no data
  no data
  no data
  1.5E+01
  no data
  8.4E+00
  6.3E+00
  4.2E+01
  no data
  no data
  no data
  no data
  no data
  no data
  no data
  no data
Weight of Evidence
Classification(d)

     B2
     B2
     B2
     B2
     A
     B2
      A

      B2
      Bl
      A
      B2
      Type of Cancer
Liver tumors
Liver tumors
Liver cancer
Liver tumors
Increased incidence of nonlymphocytic leukemia
Increased incidence or hepatocellular neoplasms
Lung cancer

Lung cancer in rats/monkeys  (inh)
Carcinogenic in mice by various  routes
Lung cancer
Renal tumors, affects gene expression
Source

 IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
 IRIS
 IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
EPA(a)
 IRIS
IRIS
 IRIS
 IRIS
 IRIS
 IRIS
IRIS
IRIS
IRIS
 IRIS
IRIS
IRIS
IRIS
-------
No Data - No value listed in reference
(Values listed in parentheses are from HEAST, were used in the absence of current IRIS values)
* CSF generated using toxicity eguivalency factors, based on benzo[a]pyrene toxicity  (see LAW, 1993)
(a)  Slope factors provided in terms of unit risk were converted prior to input on this table as follows:
    for oral route:  UNIT RISK (L/Ig)  * 1,000 Ig/mg * day/2 L * 70 kg = CSF (kg-day/mg)
    for inhalation route:  UNIT RISK  (m3/Ig)  * 1,000 Ig/mg * day/20/m3 * 70 kg = CSF  (kg-day/mg)
(b)  IRIS or HEAST listing not available for this chemical
(c)  Value is for hexavalent chromium
(d)  Weight of Evidence Classification:
    A  - Human Carcinogen
    Bl - Probable human carcinogen; limited human data available
    B2 - Probable human carcinogen; insufficient evidence in animals and inadeguate or no evidence in humans

(e)  Memorandum to Assistant Administrators. Recommended Agency Policy on the Carcinogenicity Risk Associated with the
      Ingestion of Inorganic Arsenic.   USEPA, Office of the Administrator, Washington, B.C. June 21, 1988.
-------
Medium
Surface
Soils
Subsurface
Soils
                                                              TAKLE 2-6

                                                EXPOSURE PATHWAY SUMMARY FOR THE RRA
                                                         Record of Decision
                                                          Pesticide Storage Facility
                                                            Fort Riley, Kansas
Sediment
Land Use/Populations

Current Land Use:

Landscapers

Site Workers

Utility Workers

Future Land Use:

Construction Workers

Landscapers

Recreational Children

Site Workers


Utility Workers

Current Land Use:

Landscapers


Utility Workers

Future Land Use:
Construction Workers

Landscapers

Utility Workers

Future Land Use:

Site Workers
Exposure Pathway



Dermal Contact

Dermal Contact,  Incidental Ingestion

Dermal Contact



Dermal Contact,  Incidental Ingestion

Dermal Contact

Dermal Contact

Dermal Contact,  Inhalation of Fugitive
Dust, Incidental Ingestion

Dermal Contact



Dermal Contact


Dermal Contact


Dermal Contact

Dermal Contact

Dermal Contact



Dermal Contact
-------
                                                              TABLE 2-7

                                                      SUMMARY OF HAZARD INDICES
                                                      RESIDUAL RISK ASSESSMENT
                                                         Record of Decision
                                                     Pesticide Storage Facility
                                                         Fort Riley, Kansas
RECEPTOR
                              EXPOSURE ROUTE AND MEDIUM
                                              HAZARD/INDEX
                                                                                                  TOTAL HAZARD INDEX*
Current Site Worker
Current Site Worker
Future Site Worker
Future Site Worker
Future Site Worker
Future Site Worker
Current Utility Worker
Current Utility Worker
Future Utility Worker
Future Utility Worker
Current Landscaper
Current Landscaper
Future Landscaper
Future Landscaper
Future Construction Worker
Future Construction Worker
Future Construction Worker
Incidental Ingestion of surface soil
Dermal contact with surface soil
Incidental ingestion of surface soil
Dermal contact with surface soil
Inhalation of fugitive dust
Dermal contact with sediments
Dermal contact with surface soil
Dermal contact with subsurface soil
Dermal contact with surface soil
Dermal contact with subsurface soil
Dermal contact with surface soil
Dermal contact with subsurface soil
Dermal contact with surface soil
Dermal contact with subsurface soil
Incidental ingestion of surface soil
Dermal contact with surface soil
Dermal contact with subsurface soil
0.002
0.01
0.003
0.02
 NA
0.00003
0.00002
0.00001
0.00007
0.00004
0.00005
0.000009
0.00006
0.00004
0.01
0.007
0.004
                                                                                                      0.01
                                                                                                      0.02
                                                                                                     0.00003
                                                                                                     0.00001
                                                                                                     0.00006
                                                                                                      0.0001
                                                                                                        0.02
Current/Future Recreational Child   Dermal contact with surface soil
                                                  0.0009
NA - Not assessed because toxicity data for inhalation of the chemicals of concern were not available
* Receptor-specific sums of hazard indices
-------
                                                                  TABLE 2-8

                                                           SUMMARY OF CANCER RISKS
                                                          RESIDUAL RISK ASSESSMENT
                                                             Record of Decision
                                                         Pesticide Storage Facility
                                                             Fort Riley, Kansas
    RECEPTOR
                                     EXPOSURE ROUTE AND MEDIUM
                                                                                 CANCER RISK
                                                                                                        TOTAL CANCER INDEX*
    Current Site Worker
    Current Site Worker

    Future Site Worker
    Future Site Worker
    Future Site Worker
    Future Site Worker

    Current Utility Worker
    Current Utility Worker

    Future Utility Worker
    Future Utility Worker

    Current Landscaper
    Current Landscaper

    Future Landscaper
    Future Landscaper

    Future Construction Worker
    Future Construction Worker
    Future Construction Worker
Incidental ingestion of surface soil
Dermal contact with surface soil

Incidental ingestion of surface soil
Dermal contact with surface soil
Inhalation of fugitive dust
Dermal contact with sediments

Dermal contact with surface soil
Dermal contact with subsurface soil

Dermal contact with surface soil
Dermal contact with subsurface soil

Dermal contact with surface soil
Dermal contact with subsurface soil

Dermal contact with surface soil
Dermal contact with subsurface soil

Incidental ingestion of surface soil
Dermal contact with surface soil
Dermal contact with subsurface soil
    Current/Future Recreational Child
       Dermal contact with surface soil
2E-07
1E-06

3E-07
1E-06
3E-10
8E-09

2E-09
1E-09

6E-09
5E-09

1E-09
1E-09

6E-09
5E-09

5E-08
3E-08
2E-08

NA
1E-06
1E-06
3E-09
1E-C
2E-09
1E-C
 1E-07
  NA
    NA - Not assessed because cancer risks arc not estimated for children
    * Receptor-specific sums of hazard indices
                                   ATTACHMENT


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