&ERA
United States
Environmental Protection	1200 Pennsylvania Avenue, N.W.
Agency	Washington, DC 20460	December 2013
Office of Solid Waste and Emergency Response
Support Document for the
Revised National Priorities List
Final Rule - Beck's Lake

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Support Document for the
Revised National Priorities List
Final Rule
Beck's Lake
December 2013
Site Assessment and Remedy Decisions Branch
Office of Superfund Remediation and Technology Innovation
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, DC 20460

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Table of Contents
Executive Summary	ii
Introduction	iii
Background of the NPL	iii
Development of the NPL	iii
Hazard Ranking System	iv
Other Mechanisms for Listing	v
Organization of this Document	v
Glossary	vi
1.	List of Commenters and Correspondence	1
2.	Site Description	1
3.	Summary of Comments	5
3.1	Support for Listing and Other Non-opposition Comments	5
3.2	Availability of Documentation	6
3.3	Consistency with Regulatory Requirements	7
3.4	Extent of Site	7
3.5	Consistency with Guidance	8
3.6	Establishment of Background Levels	9
3.6.1	Presentation of Background Sample Locations	11
3.6.2	Rationale for Not Using the ESI Background Level	12
3.6.3	Rationale for Not Using Sample S34 as Background	13
3.6.4	Rationale for Not Using Sample S33 as Background	15
3.6.5	Adequacy of Background Locations	16
3.6.6	Consistency of Background Sample Concentrations with the National Background Levels	17
3.6.7	Presentation of Analysis to Support the Calculation of Background Levels	18
4.	Conclusion	19
Attachment 1 -Documentation of AMEC Freedom of Information Act (FOIA) request
Attachment 2 - Element Concentrations in Soils and Other Surficial Materials of the Conterminous United
States, U. S. Geological Survey Professional Paper 1270, Shacklette and Boerngen, 1984
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Beck's Lake NPL Listing Support Document
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Executive Summary
Section 105(a)(8)(B) of CERCLA, as amended by SARA, requires that the EPA prepare a list of national
priorities among the known releases or threatened releases of hazardous substances, pollutants, or contaminants
throughout the United States. An original National Priorities List (NPL) was promulgated on September 8, 1983
(48 FR 40658). CERCLA requires that EPA update the list at least annually.
This document provides responses to public comments received on the Beck's Lake site, proposed on May 24,
2013 (78 FR 31464). This site is being added to the NPL based on an evaluation under EPA's Hazard Ranking
System (HRS) in a final rule published in the Federal Register in December 2013.
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Beck's Lake NPL Listing Support Document
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Introduction
This document explains the rationale for adding the Beck's Lake site in South Bend, Indiana to the National
Priorities List (NPL) of uncontrolled hazardous waste sites and provides responses to public comments received
on this site listing proposal. The EPA proposed this site to the NPL on May 24, 2013 (78 FR 31464). This site is
being added to the NPL based on an evaluation under the Hazard Ranking System (HRS) in a final rule published
in the Federal Register in December 2013.
Background of the NPL
In 1980, Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), 42 U.S.C. Sections 9601 et seq. in response to the dangers of uncontrolled hazardous waste sites.
CERCLA was amended on October 17, 1986, by the Superfund Amendments and Reauthorization Act (SARA),
Public Law No. 99-499, stat., 1613 et seq. To implement CERCLA, EPA promulgated the revised National Oil
and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, on July 16, 1982 (47 FR 31180),
pursuant to CERCLA Section 105 and Executive Order 12316 (46 FR 42237, August 20, 1981). The NCP, further
revised by EPA on September 16, 1985 (50 FR 37624) and November 20, 1985 (50 FR 47912), sets forth
guidelines and procedures needed to respond under CERCLA to releases and threatened releases of hazardous
substances, pollutants, or contaminants. On March 8, 1990 (55 FR 8666), EPA further revised the NCP in
response to SARA.
Section 105(a)(8)(A) of CERCLA, as amended by SARA, requires that the NCP include
criteria for determining priorities among releases or threatened releases throughout the United
States for the purpose of taking remedial action and, to the extent practicable, take into account
the potential urgency of such action, for the purpose of taking removal action.
Removal action involves cleanup or other actions that are taken in response to emergency conditions or on a
short-term or temporary basis (CERCLA Section 101). Remedial action is generally long-term in nature and
involves response actions that are consistent with a permanent remedy for a release (CERCLA Section 101).
Criteria for placing sites on the NPL, which makes them eligible for remedial actions financed by the Trust Fund
established under CERCLA, were included in the HRS. EPA promulgated the HRS as Appendix A of the NCP
(47 FR 31219, July 16, 1982). On December 14, 1990 (56 FR 51532), EPA promulgated revisions to the HRS in
response to SARA, and established the effective date for the HRS revisions as March 15, 1991.
Section 105(a)(8)(B) of CERCLA, as amended, requires that the statutory criteria provided by the HRS be used to
prepare a list of national priorities among the known releases or threatened releases of hazardous substances,
pollutants, or contaminants throughout the United States. The list, which is Appendix B of the NCP, is the NPL.
An original NPL of 406 sites was promulgated on September 8, 1983 (48 FR 40658). At that time, an HRS score
of 28.5 was established as the cutoff for listing because it yielded an initial NPL of at least 400 sites, as suggested
by CERCLA. The NPL has been expanded several times since then, most recently on May 24, 2013 (78 FR
31417). The Agency also has published a number of proposed rulemakings to add sites to the NPL. The most
recent proposal was on May 24, 2013 (78 FR 31464).
Development of the NPL
The primary purpose of the NPL is stated in the legislative history of CERCLA (Report of the Committee on
Environment and Public Works, Senate Report No. 96-848, 96th Cong., 2d Sess. 60 [1980]).
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The priority list serves primarily informational purposes, identifying for the States and the public
those facilities and sites or other releases which appear to warrant remedial actions. Inclusion of a
facility or site on the list does not in itself reflect a judgment of the activities of its owner or
operator, it does not require those persons to undertake any action, nor does it assign liability to
any person. Subsequent government actions will be necessary in order to do so, and these actions
will be attended by all appropriate procedural safeguards.
The NPL, therefore, is primarily an informational and management tool. The identification of a site for the NPL is
intended primarily to guide EPA in determining which sites warrant further investigation to assess the nature and
extent of the human health and environmental risks associated with the site and to determine what CERCLA-
financed remedial action(s), if any, may be appropriate. The NPL also serves to notify the public of sites EPA
believes warrant further investigation. Finally, listing a site may, to the extent potentially responsible parties are
identifiable at the time of listing, serve as notice to such parties that the Agency may initiate CERCLA-financed
remedial action.
CERCLA Section 105(a)(8)(B) directs EPA to list priority sites among the known releases or threatened release
of hazardous substances, pollutants, or contaminants, and Section 105(a)(8)(A) directs EPA to consider certain
enumerated and other appropriate factors in doing so. Thus, as a matter of policy, EPA has the discretion not to
use CERCLA to respond to certain types of releases. Where other authorities exist, placing sites on the NPL for
possible remedial action under CERCLA may not be appropriate. Therefore, EPA has chosen not to place certain
types of sites on the NPL even though CERCLA does not exclude such action. If, however, the Agency later
determines that sites not listed as a matter of policy are not being properly responded to, the Agency may consider
placing them on the NPL.
Hazard Ranking System
The HRS is the principle mechanism EPA uses to place uncontrolled waste sites on the NPL. It is a numerically
based screening system that uses information from initial, limited investigations ~ the preliminary assessment and
site inspection ~ to assess the relative potential of sites to pose a threat to human health or the environment. HRS
scores, however, do not determine the sequence in which EPA funds remedial response actions, because the
information collected to develop HRS scores is not sufficient in itself to determine either the extent of
contamination or the appropriate response for a particular site. Moreover, the sites with the highest scores do not
necessarily come to the Agency's attention first, so that addressing sites strictly on the basis of ranking would in
some cases require stopping work at sites where it was already underway. Thus, EPA relies on further, more
detailed studies in the remedial investigation/feasibility study that typically follows listing.
The HRS uses a structured value analysis approach to scoring sites. This approach assigns numerical values to
factors that relate to or indicate risk, based on conditions at the site. The factors are grouped into three categories.
Each category has a maximum value. The categories are:
•	likelihood that a site has released or has the potential to release hazardous substances into the
environment;
•	characteristics of the waste (e.g., toxicity and waste quantity); and
•	targets (e.g., people or sensitive environments) affected by the release.
Under the HRS, four pathways can be scored for one or more threats as identified below:
•	Ground Water Migration (Sgw)
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•	Surface Water Migration (Ssw)
The following threats are evaluated for two separate migration components, overland/flood migration and
ground water to surface water.
-	drinking water
-	human food chain
-	sensitive environments
•	Soil Exposure (Ss)
-	resident population
-	nearby population
•	Air Migration (Sa)
After scores are calculated for one or more pathways according to prescribed guidelines, they are combined using
the following root-mean-square equation to determine the overall site score (S), which ranges from 0 to 100:
If all pathway scores are low, the HRS score is low. However, the HRS score can be relatively high even if only
one pathway score is high. This is an important requirement for HRS scoring because some extremely dangerous
sites pose threats through only one pathway. For example, buried leaking drums of hazardous substances can
contaminate drinking water wells, but ~ if the drums are buried deep enough and the substances not very volatile
-- not surface water or air.
Other Mechanisms for Listing
There are two mechanisms other than the HRS by which sites can be placed on the NPL. The first of these
mechanisms, authorized by the NCP at 40 CFR 300.425(c)(2), allows each State and Territory to designate one
site as its highest priority regardless of score. The last mechanism, authorized by the NCP at 40 CFR
300.425(c)(3), allows listing a site if it meets the following three requirements:
•	Agency for Toxic Substances and Disease Registry (ATSDR) of the U.S. Public Health Service has
issued a health advisory that recommends dissociation of individuals from the release;
•	EPA determines the site poses a significant threat to public health; and
•	EPA anticipates it will be more cost-effective to use its remedial authority than to use its emergency
removal authority to respond to the site.
Organization of this Document
The following section contains EPA responses to site-specific public comments received on the proposal of the
Beck's Lake site on May 24, 2013 (78 FR 31464). The site discussion begins with a list of commenters, followed
by a site description, a summary of comments, and Agency responses to each comment. A concluding statement
indicates the effect of the comments on the HRS score for the site.
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Glossary
The following acronyms and abbreviations are used throughout the text:
Agency	U.S. Environmental Protection Agency
AM EC	AMEC Environment & Infrastructure, Inc.
AOC	Area of Observed Contamination
APA	Administrative Procedure Act
ATSDR	Agency for Toxic Substances and Disease Registry
CERCLA	Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42
U.S.C. Sections 9601 etseq., also known as Superfund
CFR	Code of Federal Regulations
EPA	U.S. Environmental Protection Agency
ESI	Expanded Site Inspection
FOIA	Freedom of Information Act
FR	Federal Register
HRS	Hazard Ranking System, Appendix A of the NCP
HRS score Overall site score calculated using the Hazard Ranking System; ranges from 0 to 100
IDEM	Indiana Department of Environmental Management
mg/kg	Milligram per kilogram
NCP	National Oil and Hazardous Substances Pollution Contingency Plan, 40 C.F.R. Part 300
NPL	National Priorities List, Appendix B of the NCP
PPM	Parts per million
PA/SI	Preliminary Assessment and Site Inspection
Rl	Remedial Investigation
SARA	Superfund Amendments and Reauthorization Act
USGS	United States Geological Survey
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Beck's Lake NPL Listing Support Document
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1.	List of Commenters and Correspondence
EPA-HQ-SFUND-2013-0196-0004 Correspondence, dated February 1, 2012, from Thomas W.
Easterly, Commissioner, Indiana Department of Environmental
Management
EPA-HQ-SFUND-2013-0196-0005 Correspondence, dated February 5, 2013, from Bruce H. Palin,
Assistant Commissioner, Office of Land Quality, Indiana
Department of Environmental Management
EPA-HQ-SFUND-2013-0196-0006 Comment, dated June 20, 2013, handwritten comments from
participants of two community meetings held by EPA on June
13, 2013, regarding the Beck's Lake site, South Bend, IN
EPA-HQ-SFUND-2013-0196-0007 Comment, dated July 23, 2013, from Stephen D. Murray, CPG,
Principal Project Manager and Peter D. Neithercut. PE, Senior
Principal Engineer, AMEC Environment & Infrastructure, Inc.,
at the request of Honeywell International
2.	Site Description
The Beck's Lake site consists of a landfill and contaminated soil located at and near the intersection of
Washington and Falcon Streets and adjacent to LaSalle Park on the northwest side of South Bend, Indiana (see
Figures 1 and 2 of this support document). The area surrounding LaSalle Park consists mostly of older single- and
multi-family residences in a typical urban setting. Directly adjacent to LaSalle Park on the west across Falcon
Street is a new complex of subsidized housing and apartments called LaSalle Park Homes. Portions of the current
LaSalle Park were used as a dump and landfill from approximately 1938 through the mid-1950s. Numerous
companies and individuals have reportedly dumped a variety of materials containing hazardous substances at this
location; these materials include asbestos, plating wastes, solvents, paint wastes, sludges, and foundry sand.
Foundry sand and sludge contain arsenic and other contaminants.
The area of concern includes the dump area and the area immediately surrounding LaSalle Park to the west and
south-southwest where levels of arsenic elevated above background levels were identified during the 2001
Brownfields Environmental Assessment and the 1996 initial Expanded Site Inspection (ESI) for the Site. In a
1951 historical aerial photograph of the area, the dumping area is evident and appears to extend to the edge of the
partial road which is now Falcon Street. Also visible on the photograph are truck paths extending beyond the edge
of the partial road into the area that is now part of the LaSalle Park Homes. Therefore, it appears from historical
aerial photographs that before the LaSalle Park Homes were built, the waste that was deposited in the Beck's
Lake landfill could also have been deposited on the current LaSalle Park Homes property.
Results of the 2009 ESI (the ESI 2) included three soil samples collected at the LaSalle Park Homes, which
contain arsenic at concentrations above background and above health-based benchmarks. These three samples
(indicated on Figures 1 and 2 of this support document as samples S3, S8 and S14) comprise the area of observed
contamination (AOC) at the Site. The targets at the Site include 89 homes within 200 feet of the AOC that are
scored at Level I contamination based on these three soil samples at the LaSalle Park Homes residential
properties.
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Beck's Lake NPL Listing Support Document
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Table 1 shows arsenic concentrations found in background, "step out"1, and observed contamination samples
identified during the Hazard Ranking System (HRS) evaluation.
Table 1: Background, "Step Out" and Observed Contamination
Sample Arsenic Concentrations
(Concentrations from Reference 14 of the HRS Documentation Record)
Background Samples
Sample ID
Arsenic Concentration (mg/kg)
S31
2.7
S32
3.4
S35
9.7
S36
9.7
S37
7.9
"Step Out" Samples
Sample ID
Arsenic Concentration (mg/kg)
S3
28.3
S23 (duplicate of S3)
28.7
S33
7.8
S34
12.9
S39
25
Observed Contamination Samples
Sample ID
Arsenic Concentration (mg/kg)
S6
34.3
S8
29.4
S9 (duplicate of S8)
32.7
S14
30.8
1 "Step out" samples are soil samples that are collected at increasing distance from the center of contamination to determine
the geographic extent of contamination.
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Becks Lake NPL Listing Support Document
N
December 2013
Arsenic Concentrations for Beck's Lake
EPA ID Number INO980904379
South Bend, St. Joseph County

Figure 1 - Map of soil sample locations at the Beck's Lake site. (Figure 1 is based on page 1 of Reference 14 of the HRS documentation record at
proposal, and has been modified to add locations of background samples and samples that meet observed release criteria; this figure includes all of
the soil sample locations identified in the Beck's Lake HRS documentation record at proposal.)
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Beck's Lake NPL Listing Support Document
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10/6/2009
S40
Arsenic =12.3 mg/Kg
10/6/2009
S11 and S12 (dup)
Arsenic = 8.8 and 6.1 mg/Kg
10/6/2009
S15
Arsenic
10/6/2009
S13
Arsenic = 12.9 mg/Kg
10/6/2009
S53 (3 to 5 ft)
Arsenic = 21.5 mg/Kg
10/6/2009
S16
Arsenic = 4.1 mg/Kg
10/6/2009
S55 (2 to 5 ft)
Arsenic = 18.4 mg/Kg
10/6/2009
S39
*nic = 25 mg/Kg
10/6/2009
S14
Arsenic 30.8 mg/Kg
10/6/2009
S52 (2 to 4 ft) and S56 (2 to 5 ft)
Arsenic = 12 and 24.5 mg/Kg
10/6/2009
S54 (4 to 5 ft)
Arsenic = 11.9 mg/Kg
10/6/2009
S5
Arsenic = 15.1 mg/Kg
10/6/2009
S51 (6 to 7 ft)
Arsenic = 7 mg/Kg
10/6/2009
S19
Arsenic
10/6/2009
S6
Arsenic = 34.3 mg/Kg
1 0/6/2009
S8 and S9 (dup)
Arsenic = 29.4 and 32.7 mg/Kg
10/6/2009
S17 and S24 (dup)
Arsenic = 12.2 and 10.3 mg/Kg
.Washington St
3 mg/Kg
10/6/2009
S22
enic = 8.2 mg/Kg
10/5/2009
S1
Arsenic = 13.9 mg/Kg
10/6/2009
S21
Arsenic = 9.1 mg/Kg
10/5/2009
S2
Arsenic = 11.5 mg/Kg
10/6/2009
S10
Arsenic « 29 mg/Kg
10/6/2009
S20
Arsenic =12.2 mg/Kg
'Jefferson Blvd
10/6/2009
S4
Arsenic =15.9 mg/Kg
Figure 2 - Enlarged map of Figure 1 showing soil sample locations centered on and around the LaSalle Park area at the Beck's Lake site.
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3. Summary of Comments
Thomas W. Easterly, Commissioner of the Indiana Department of Environmental Management, recommended
that the Beck's Lake site be placed on the NPL, as did 56 participants at two community meetings regarding the
Beck's Lake site. These meetings took place on June 13, 2013, organized by the U.S. Environmental Protection
Agency (EPA), Region 5.
AMEC Environment & Infrastructure, Inc. (AMEC), at the request of Honeywell International, submitted
comments in opposition to placing the Beck's Lake site on the NPL. AMEC commented that neither the EPA nor
the Indiana Department of Environmental Management (IDEM) followed the HRS or HRS guidance in placing
the Site on the NPL. AMEC also commented that the EPA failed to provide a rationale for determining the
background level for arsenic.
AMEC commented that the background concentrations used during the HRS evaluation did not accurately reflect
background levels identified during sampling events. AMEC's main eligibility comment concerned the
identification of the background level for arsenic used in the HRS evaluation. AMEC commented that the HRS
evaluation used a different background determination than the 2009 ESI Report. AMEC further asserted that if the
background level used in the 2009 ESI Report were used, then the arsenic results used in the HRS evaluation
would not exceed the three times-background concentration threshold.
Additionally, AMEC asserted that the HRS evaluation did not provide rationale for sample selection for
background samples. AMEC further commented that an insufficient number of background samples were
collected to adequately determine a background threshold level.
Finally, AMEC commented that the documentation provided "to date" (at the time of its comments dated July 23,
2013) did not identify the background sample locations. AMEC commented that it requested documentation that
would identify the sample locations, but because the work plan (for the Expanded Site Inspection) was not
available through the IDEM virtual file cabinet, AMEC commented that it was not able to determine the
background sample locations.
3.1 Support for Listing and Other Non-opposition Comments
Comment: On February 5, 2013, Bruce H. Palin, Assistant Commissioner, Office of Land Quality, Indiana
Department of Environmental Management (IDEM), wrote to convey IDEM Commissioner Thomas W.
Easterly's continued support for listing the Beck's Lake site on the National Priorities List (NPL).
A total of 56 written comments from concerned citizens in support of placing the Beck's Lake site on the NPL
were collected by the EPA Region 5, during two community meetings regarding the Beck's Lake site it held on
June 13, 2013.
Response: The Beck's Lake site is being added to the NPL. Listing makes a site eligible for remedial action
funding under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), and the
EPA will examine the Site to determine the appropriate response action(s). Actual funding may not necessarily be
undertaken in the precise order of HRS scores. In addition, upon more detailed investigation remedial action may
not be necessary at all in some cases. The need for using Superfund monies for remedial activities will be
determined on a site-by-site basis, taking into account the NPL ranking, State priorities, further site investigation,
other response alternatives, and other factors as appropriate.
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3.2 Availability of Documentation
Comment: AMEC commented that the documentation provided "to date" (at the time of its comments dated July
23, 2013) did not identify the background sample locations. AMEC commented that it requested documentation
that would identify the sample locations, but because the work plan (for the Expanded Site Inspection) was not
available through the IDEM virtual file cabinet, AMEC commented that it was not able to determine the
background sample locations. AMEC commented that it requested the work plan but did not receive the document
prior to submitting comments.
Response: The HRS documentation record at proposal describes the background sample locations and Reference
14 was cited to identify the background sample locations in a figure; this reference was available at the time of
proposal (May 24, 2012). The work plan for the expanded site inspection (ESI) was publicly available as
Reference 12 of the HRS documentation record at proposal; it was available in the EPA Region 5 Docket at the
time of proposal. In addition, AMEC received the work plan on July 22, 2013, (which is within the comment
period, which ended July 23, 2013 at 11:59 pm, for the proposed rule) via a FOIA request (see Attachment 1 of
this support document and details of the FOIA request described below).
To obtain the HRS documentation package for this site (including Reference 12 to the HRS documentation
record), the preamble to the proposed rule in the Federal Register notice (78 FR 31464, May 24, 2013) instructs:
You may view the documents, by appointment only, in the Headquarters or the Regional Dockets
after the publication of this proposed rule. The hours of operation for the Headquarters Docket are
from 8:30 a.m. to 4:30 p.m., Monday through Friday excluding federal holidays. Please contact
the Regional Dockets for hours....
You may also request copies from the EPA Headquarters or the Regional Dockets. An informal
request, rather than a formal written request under the Freedom of Information Act, should be the
ordinary procedure for obtaining copies of any of these documents. Please note that due to the
difficulty of reproducing oversized maps, oversized maps may be viewed only in-person; since
the EPA dockets are not equipped to either copy and mail out such maps or scan them and send
them out electronically.
Regarding AMEC's specific request for additional documentation (the work plan), while no specific information
was provided by AMEC in its comments about its requests for documentation, a FOIA request by Mr. Steven E.
Murray of AMEC was submitted on June 21, 2013, to which the EPA fully responded (see Attachment 1 of this
support document for supporting documentation). The FOIA request, which included the work plan in question
(Reference 12 of the HRS documentation record at proposal), was completed within the time outlined on the
request and the request was fulfilled on July 22, 2013, before the comment period closing date which ended July
23, 2013 at 11:59 pm (see Attachment 1 of this support document).
As stated in the preamble to the proposed rule, the documents that were requested through the FOIA request were
available in the EPA Region 5 docket and were accessible throughout the comment period. While AMEC did not
follow the procedures outlined in the preamble to the proposed rule, these documents were available to the public
throughout the comment period (comments regarding the documentation of the sample locations are discussed in
section 3.6.1, Presentation of Background Sample Locations, of this support document); the preamble clearly
stated how to expeditiously obtain the documents and made clear that a formal FOIA request was not the usual
procedure for doing so.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
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3.3	Consistency with Regulatory Requirements
Comment: AMEC commented that the proposed listing is "not consistent with regulatory requirements." AMEC
particularly commented that the "background threshold" had not been established according to guidance. AMEC
argued that the Site should not be listed on the NPL because the information provided to date has not provided a
rationale for determining background levels.
Response: All administrative and regulatory requirements for placing the Beck's Lake site on the NPL in the
National Oil and Hazardous Substances Pollution Contingency Plan, the NCP, (Code of Federal Regulations [40
CFR 300]) including those in the HRS (40 CFR 300, Appendix A) have been met. This includes those
requirements for establishing the background threshold used in the HRS evaluation. The evaluation of the Site
using the HRS and the listing of the Site on the NPL are consistent with CERCLA, its associated regulatory
requirements, and the Administrative Procedure Act (APA) (78 FR 31464, May 24, 2013). The CERCLA
requirements for placing the Beck's Lake site on the NPL are embodied in the NCP (40 CFR 300).
Public notice of the proposal of the Site was published in the Federal Register on May 24, 2013 (78 FR 31464).
The HRS score of 50.00 forthe Site is above the listing cut off score of 28.50 (78 FR 31466, May 24, 2013). The
rationale for the score is presented in the HRS documentation package and is consistent with the HRS. Public
notice of the proposal to add the site to the NPL and the rationale for the score were made available to the public
at the time of proposal (78 FR 31464, May 24, 2013). This support document responds to all comments submitted
on the proposed action, including comments regarding the rationale for the determination of the background level
used to identify a significant increase in arsenic levels due to a release from the Site.
Regarding establishment of a background threshold, as discussed in section 3.6, Establishment of Background
Levels, of this support document, the background threshold used to document an area of observed exposure was
correctly determined consistent with HRS Sections 2.3, Likelihood of release, and 5.0.1, General considerations.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.4	Extent of Site
Comment: AMEC commented that the HRS documentation record does not clearly define the boundaries of the
proposed site.
Response: At the listing stage of the Superfund process, the final site boundaries are not determined. For HRS
scoring purposes, the Beck's Lake site, as discussed on page 9 of the HRS documentation record at proposal,
"consists of a landfill and contaminated soil located at and near the intersection of Washington and Falcon streets
on the northwest side of South Bend, Indiana, and adjacent to LaSalle Park (Ref. 5, p. 13)."
As stated on page 1 of the HRS documentation record at proposal, the boundaries of the Site are not exactly
delineated:
The street address, coordinates, and contaminant locations presented in this HRS documentation
record identify the general area the Site is located. They represent one or more locations EPA
considers to be part of the Site based on the screening information EPA used to evaluate the Site
for NPL listing. EPA lists national priorities among the known "releases or threatened releases"
of hazardous substances; thus, the focus is on the release, not precisely delineated boundaries.
... Generally, HRS scoring and the subsequent listing of a release merely represent the initial
determination that a certain area may need to be addressed under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA). Accordingly, EPA
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contemplates that the preliminary description of facility boundaries at the time of scoring will be
refined as more information is developed as to where the contamination has come to be located.
Additionally, as explained in Part I, Section F, Does the NPL Define Boundaries of Sites?, of the Federal Register
notice announcing proposal to add the Site to the NPL (78 FR 31464, May 24, 2013):
The NPL does not describe releases in precise geographical terms; it would be neither feasible
nor consistent with the limited purpose of the NPL (to identify releases that are priorities for
further evaluation), for it to do so. Indeed, the precise nature and extent of the site are typically
not known at the time of listing. Although a CERCLA "facility" is broadly defined to include any
area where a hazardous substance has "come to be located" (CERLCA section 101(9)), the listing
process itself is not intended to define or reflect the boundaries of such facilities or releases . . . [,
and] while geographic terms are often used to designate the site (e.g., the "Jones Co. plant site")
in terms of the property owned by a particular party, the site, properly understood, is not limited
to that property (e.g., it may extend beyond the property due to contaminant migration), and
conversely may not occupy the full extent of the property (e.g., where there are uncontaminated
parts of the identified property, they may not be, strictly speaking, part of the "site").
Thus, the final site boundaries are not determined at the listing stage of the Superfund process and the HRS
evaluation appropriately evaluated the extent of the Site for listing purposes.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.5 Consistency with Guidance
Comment: AMEC commented that "neither EPA nor IDEM appear to have followed relevant guidance on
determining the appropriate background threshold level for arsenic." AMEC stated that "EPA did not utilize a
consistent evaluation process for developing a reasonable determination of background arsenic levels, or even one
rooted in the relevant technical guidance." AMEC commented that the "EPA has published guidance for
calculating background concentrations at CERCLA Sites (EPA, 2002 EPA 540-R-01-003) and (EPA, 2007,
EPA/600/R-07/020)" and that IDEM provides relevant guidance in Section 6.1 of IDEM's Remediation Closure
Guidance. AMEC specifically pointed out that the IDEM guidance states that 8-10 samples should be used to
calculate the background threshold value.
Response: The EPA applied the HRS to place the Site on the NPL. The background threshold value used to
establish observed contamination at the Beck's Lake site in the HRS evaluation was determined consistent with
the HRS. That is, the background threshold is three times the background concentration (level), and
concentrations at or above that threshold are used to establish observed release (see section 3.6, Establishment of
Background Levels, of this support document for a full discussion). The three guidance documents that AMEC
cited in its comments are not applicable to an HRS evaluation; rather, they are applicable to making a site-
specific, risk-based remedial decision, which is not required when placing a site on the NPL. An HRS evaluation
is based on screening data gathered during the preliminary assessment and site inspection (PA/SI) stage of the
CERCLA process and occurs before a site is placed on the NPL. Therefore, the guidance cited by AMEC applies
to different stages in the CERCLA process or in the State of Indiana site closure process, which require more
extensive site data collection efforts than undertaken during the PA/SI. Furthermore, the "background" discussed
in the guidance documents cited by AMEC is used for different purposes than in an HRS evaluation.
Specifically, the 2002 EPA guidance (EPA, 2002 EPA 540-R-01-003, Guidance for Comparing Background and
Chemical Concentrations in Soil for CERCLA Sites), which AMEC cites in its comment, was developed for the
remedial investigation (RI) stage of the CERCLA site remediation process that occurs after a site is placed on the
NPL. Section 1.1, Application of Guidance, of the 2002 EPA guidance states: "This guidance should be applied
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on a site-specific basis, with assistance from a statistician who is familiar with the CERCLA remedial
investigation process." The RI requires a more intense data collection effort that includes more field sampling to
gain an expanded understanding of the issues at the site. The background level in the RI stage is used to establish
the extent of the release and the risk level posed by the release from the site; whereas, the HRS evaluation
establishes that observed contamination has occurred and that a site merits further investigation to determine the
extent of the release and risk level. Establishing this risk background level requires a more intensive site
evaluation effort than the PA/SI that is the basis of the HRS evaluation. Thus, the cited 2002 EPA guidance is not
appropriate for use in determining the background level concentration of arsenic in an HRS evaluation.
The 2007 EPA document (EPA, 2007, EPA/600/R-07/020, Performance of Statistical Tests for Site Versus
Background Soil Comparisons When Distributional Assumptions Are Not Met2) cited by AMEC in its comments
also is not appropriate to be used as guidance when determining an HRS background threshold. The 2007 EPA
document is a research paper exploring the performance of different statistical tests on background and "site" soil
samples when the data has an unknown population distribution. The 2007 document states that for unknown
population distributions, a sample size of at least 60 is required to meet the assumptions of the statistical tests
performed (both background and "site" sample groups should contain, at a minimum, 30 samples). The 2007 EPA
document uses a data set of more than 30 background samples and 122 total samples. As discussed above, this
data collection effort is beyond the scope of a PA/SI that is the basis of an HRS evaluation and beyond the level
of data available at this site. Additionally, the 2007 EPA document does not address the listing process or
Superfund. The HRS evaluation of the Beck's Lake site was based on data from 5 background samples and 35
total samples. Thus, the 2007 document is not appropriate as guidance for assigning background concentrations in
an HRS evaluation.
Regarding AMEC's comment that IDEM provides relevant guidance to establish site-specific background
concentrations in its Remediation Closure Guidance document (IDEM, Remediation Closure Guide, March 22,
2012, Section 6), this guidance document pertains to remediation efforts (see page 12 in section 1.2, Applicability,
of the Remediation Closure Guide) and is not applicable to stages of CERCLA prior to site listing. As with the
two cited EPA documents, IDEM's guidance document was developed to evaluate sites later in the site
investigation process; the data requirements of the site remediation stage of CERCLA require a larger data
collection effort than the limited data available at the time of an HRS evaluation.
The method used in the HRS evaluation to assign a background level at the Beck's Lake site is consistent with the
HRS, and is consistent with the only relevant guidance (The Hazard Ranking System Guidance Manual, Interim
Final, November 19923 [HRS Guidance Manual]) (see section 3.6, Establishment of Background Levels, of this
support document).
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.6 Establishment of Background Levels
Comment: AMEC commented that the EPA provided no rationale or documentation of the background analysis
for how the agency selected the samples that were used to establish the background level of arsenic at the Site.
AMEC challenged the technical basis for the selected arsenic background level specifically:
• The selection of the background samples included in calculating the background level
o The rationale for selecting background samples in the HRS documentation record
o The rationale for not using the background level identified in the ESI
2	An electronic copy of this report is available at: http://www.epa. gov/esd/cmb/pdf/14 lpos07.pdf
3	An electronic copy of the HRS Guidance Manual is available at: http://www.epa.gOv/superfund/sites/npl/hrsres/#HRS
Guidance (accessed 8/27/2013)
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o The rationale for not using samples S33 and S34 as background samples
•	The consistency of background samples with the national background levels
•	The presentation of analysis to support the HRS documentation record background level
Response: The rationale for selecting the soil samples that were used to establish the background level4 of arsenic
at the Site is provided in the HRS documentation record at proposal. The rationale provided in the HRS
documentation record for selecting background samples is consistent with the HRS, and the background level for
arsenic was correctly established according to the HRS.
Section 5.0.1, General considerations, of the HRS describes how background samples can be identified and
states:
• Consider observed contamination to be present at sampling locations where analytic
evidence indicates that:
-A hazardous substance attributable to the site is present at a concentration
significantly above background levels for the site (see Table 2-3 in section 2.3 for the
criteria for determining analytical significance), and...
HRS Section 2.3, Likelihood of release, directs the scorer to use Table 2-3 for the soil exposure and states:
[T]he criteria in Table 2-3 are also used in establishing observed contamination for the soil
exposure pathway.
HRS Table 2-3, Observed Release Criteria for Chemical Analysis, describes how an observed release sample is
compared to a background sample and states:
Sample Measurement < Sample Quantitation Limit3
No observed release is established.
Sample Measurement > Sample Quantitation Limit3
An observed release is established as follows:
•If the background concentration is not detected (or is less than the detection limit), an
observed release is established when the sample measurement equals or exceeds the sample
quantitation limit.3
•If the background concentration equals or exceeds the detection limit, an observed
release is established when the sample measurement is 3 times or more above the
background concentration, [emphasis added]
The HRS documentation record identifies the background samples used in determining the observed
contamination.
Page 24 of the HRS documentation record at proposal provides the rationale for the selection of the background
level used in establishing observed contamination:
4 Background samples are discrete samples used to establish a background level of a concentration of a hazardous substance.
The background level provides a reference point to determine whether an observed release of a contaminant has occurred.
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Arsenic concentrations ranged from 2.7 to 9.7 mg/kg in the five background samples (S31, S32,
S35, S36 and S37) collected during the ESI 2 (Refs. 5, pp. 133, 134, 196; 17, pp. 61, 62, 64, 77-
76, 106, 109, 115-117). The highest concentration of arsenic (9.7 mg/kg) was detected in the
background samples S35 and S36 (Refs. 5, pp. 196, 17, pp. 115, 116). Three times the highest
background concentration for arsenic is 29.1 mg/kg (3 times 9.7 mg/kg)...
The HRS documentation record at proposal provides the rationale for identifying the background sample locations
used to establish observed contamination. Page 19 of the HRS documentation record at proposal states:
The background soil samples for this investigation were collected from the residential properties
away from Beck's Lake (Ref. 5, p. 18). .. .These locations were chosen to represent background
conditions because: (1) the soil type at the background sample locations are similar to the soil
types at the locations of samples collected from Area of Observed Contamination (AOC) A; (2)
theses sampling locations are at a distance away from Beck's Lake and appear to be minimally
affected by operations at Beck's Lake; (3) samples were collected within same time period
(October 5 and 6, 2009), therefore, under the same weather conditions; (4) samples were
collected at the same depth of 0 to 6-inches; (5) samples were collected by the same sampling
team and samples were collected in accordance with the approved Work Plan (Refs. 5, p. 18; 12,
pp. 1-19; 13, pp. 1-14).
The HRS documentation record provided a rationale for selecting the background sample locations as well as the
background level that was chosen to identify observed contamination. The background samples were collected
from residential properties away from the Beck's Lake Park. Multiple background samples were collected
because the extent of contamination at the Site has not been determined. Samples farthest from the center of
contamination (the AOC) were chosen as the most representative of background conditions; the background
sample with the highest concentration of arsenic was chosen for the background level (9.7 mg/kg) (see Figure 1 of
this support document). The background level was established according to the HRS and the EPA provided a
reasonable explanation for choosing the background level in the HRS documentation record at proposal. The
following subsections address AMEC's specific comments regarding the establishment of a background arsenic
level at the Site.
•	3.6.1	Presentation of Background Sample Locations
•	3.6.2	Rationale for Not Using the ESI Background Level
•	3.6.3	Rationale for Not Using Sample S34 as Background
•	3.6.4	Rationale for Not Using Sample S33 as Background
•	3.6.5	Adequacy of Background Locations
•	3.6.6	Consistency of Background Sample Concentrations with the National Background Levels
•	3.6.7	Presentation of Analysis to Support the Calculation of Background Levels
3.6.1 Presentation of Background Sample Locations
Comment: AMEC commented that the "documentation provided to date does not identify the specific sample
locations used for calculating [a] background [level]" and stated that "in fact the exact locations are redacted from
the available documentation."
Response: As referenced on page 20 of the HRS documentation record at proposal, the background sample
locations were identified in Reference 5 and depicted in Reference 14 (see also Figure 1 of this support document)
of the HRS documentation record at proposal.
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Page 20 of the HRS documentation record at proposal directs the reader to the references in the HRS package that
illustrate the background soil sample locations:
The locations of the background soil samples are described in Reference 5, page 18 and depicted
in Reference 14, page 1. [emphasis added]
As discussed previously in section 3.2, Availability of Documentation, of this support document, HRS
documentation record references are available in the Region 5 Docket. AMEC obtained these materials via a
FOIA request (see section 3.2, Availability of Documentation, and Attachment 1 of this support document).
The Agency is unsure where AMEC is referring to that the sample locations are redacted. If AMEC is referring to
the figures in Appendix C, F and G to Reference 5 of the HRS documentation record at proposal, the background
sample locations are not redacted in these figures; rather, the sample locations were cropped out of the figures
when the figures were blown up to show a more detailed view of the landfill area of the Site. Because these
samples were cropped out of these figures, Reference 14 of the HRS documentation record at proposal was cited;
Reference 14 is a figure showing all sample locations used in the establishment of observed contamination.
This comment results in no change to the HRS score and no change in the decision to place the site on the NPL.
3.6.2 Rationale for Not Using the ESI Background Level
Comment: AMEC commented that the 2009 ESI Report author used background sample S37 (7.9 mg/kg) to
"establish the 3x background threshold of 23.7 mg/kg for arsenic." AMEC commented that there was no
explanation as to why samples S35 or S36 (which both contained 9.7 mg/kg arsenic) were not used to establish
the background level in the 2009 ESI Report. AMEC also commented that there is no explanation as to why the
HRS documentation record used a background value of 9.7 mg/kg and not the same value that was used in the
2009 ESI Report.
Response: The background level of 9.7 mg/kg for arsenic in soil and a background threshold of 29.1 mg/kg for
arsenic used to establish observed contamination in the HRS documentation record at proposal are entirely
reasonable for the purpose of establishing a significant increase in arsenic levels at the Site. This background level
for arsenic was chosen for the HRS evaluation because it was the highest arsenic level in all the background
samples. As such, it represents the highest arsenic concentration that could be present at the Site had a release
from the site not occurred. As presented in Figure 1 of this support document, samples S35 and S36 were located
at similar distances from the center of arsenic concentration5 as S37 and thus were just as likely to reflect
background arsenic concentrations in the vicinity of the site as S37 (i.e., levels present in the absence of the
release being evaluated). While the background level established in the HRS documentation record is different
from the background value in the 2009 ESI Report, the value assigned at proposal is a site-specific background
level that is actually higher than the value used in the 2009 ESI Report and results in a higher background
threshold level (29.1 versus 23.7 mg/kg). That a different document, the 2009 ESI Report, selected a different,
lower background level does not alter this finding or show the rationale used in the HRS evaluation was incorrect.
As quoted in section 3.6 of this support document, to establish a significant increase in a hazardous substance
concentration and thus establish observed contamination at a sample location, HRS Table 2.3 requires a threefold
increase in release sample concentration above background levels when the background concentration is above
the detection limit (see HRS sections 5.0.1 and 2.3 as quoted in section 3.6 of this support document).
5The "center of arsenic contamination" (the AOC) refers to the area of contaminated soil samples at Beck's Lake that
contains arsenic concentrations above 30 mg/kg arsenic. These samples are identified in figure 1 of this support document.
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The HRS documentation record explains on page 24 that a value of 9.7 mg/kg arsenic was used as a background
level because it was the highest concentration determined in any of the background samples:
Arsenic concentrations ranged from 2.7 to 9.7 mg/kg in the five background samples (S31, S32,
S35, S36 and S37) collected during the ESI 2 (Refs. 5, pp. 133, 134, 196; 17, pp. 61, 62, 64, 77-
76, 106, 109, 115-117). The highest concentration of arsenic (9.7 mg/kg) was detected in the
background samples S35 and S36 (Refs. 5, pp. 196, 17, pp. 115, 116).
As quoted above and shown in Reference 5 (2009 ESI Report) to the HRS documentation record at proposal, the
background sample concentrations for arsenic at the Site ranged from 2.7 to 9.7 mg/kg. As explained on page 24
of the HRS documentation record at proposal, the EPA established the background level using the highest
concentration of arsenic found in the designated background samples (as noted in section 3.6 of this support
document, the background sample locations were chosen based on several reasons, including distance from the
Site). Since background samples S35 and S36 were found to contain 9.7 mg/kg arsenic, as documented in the data
from the 2009 ESI Report, the HRS documentation record established the background level of 9.7 mg/kg, the
highest concentration identified in any background sample. Using the highest background sample concentration
assures that the HRS requirement of a threefold increase above background concentration has been met at the Site.
Regarding the comment that the 2009 ESI Report does not provide an explanation for not using the arsenic
concentrations in samples S35 and S36 as the background level, the ESI background level rationale is not required
to be used in the HRS evaluation. As part of the HRS scoring process, the EPA determined that sample locations
S35 and S36 were as representative of background conditions as the sample S37 background location, and
determined that there was no reason to not use the higher concentrations, which in fact make the presence of
contamination more of a certainty than using a lower concentration, in setting the background level.
However, even if the EPA had identified the background level at the Site as 7.9 mg/kg (and a background
threshold of 23.7 mg/kg) consistent with the 2009 ESI Report, there would be no negative impact to the Site score
or the listing decision. In fact, in that case arsenic concentrations from more sample locations would qualify as
meeting observed contamination (three times background level) and the AOC would expand (e.g., samples S39
[25 mg/kg], S3 [28.3 mg/kg], and S23 [28.7 mg/kg] would meet observed release requirements; see Figure 1 of
this support document). This impact would only increase the extent of AOC at the site and possibly raise the
targets score.
Furthermore, if during further investigation of a site, a different background level is selected, e.g., for purposes of
determining acceptable risk or extent of remediation (if remediation is determined to be necessary), that value will
be used for those purposes; however, that value does not necessarily apply for HRS purposes.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.6.3 Rationale for Not Using Sample S34 as Background
Comment: AMEC commented that soil sample S34 was identified as a background sample in the 2009 ESI Report
but was not used as a background sample in the HRS documentation record. AMEC noted that the HRS
documentation record states that sample S34 was "mistakenly identified as a background sample" but the 2009
ESI Report did not reflect the same concern. AMEC commented that while IDEM attests that sample S34 was
collected as a "step out" sample due to elevated levels of arsenic in sample S3 and its duplicate S23, the levels in
samples S3 and S23 are not three times the threshold concentration presented in the HRS documentation record.
Finally, AMEC commented that if S34 were used to establish the background threshold concentration, no arsenic
results would meet the observed release criteria in the HRS and there would be no reason to list the Site on the
NPL.
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Response: Sample S34 was not selected as a representative background sample for establishing observed
contamination because the sample location was sufficiently close to other samples that indicate elevated arsenic
concentrations, and it (sample S34) was not determined to be outside of the contamination influence from the
Site; therefore sample S34 was not determined to be representative of background conditions. This was supported
by the finding that samples at greater distances from the site contamination but in the same general direction,
showed a further decrease in arsenic levels with increased distance.
Page 21 of the HRS documentation record at proposal provides an explanation for why sample S34 was not used
in calculating the background level:
The highest arsenic concentration in the background soil samples was 9.7 mg/kg in samples S35
and S36 (Ref 5, p. 196). Surface soil sample S34 was mistakenly identified as background sample
in 2009 ESI 2 Report (Refs. 5, p. 18; 11, p. 1)...
Sample S34 was included in the Sample Location and Comment Table on page 18 of the 2009 ESI Report, but
was not used in determining a background level in the 2009 ESI Report. Page 19 of the 2009 ESI Report identifies
the highest background concentration of arsenic as 7.9 mg/kg, which is below the 12.9 mg/kg concentration of
sample S34, as indicated on page 196 of the 2009 ESI Report. This indicates that the 2009 ESI Report did not
select sample S34 as representative of background conditions. Sample S34 was identified as a "step out" sample
because it showed decreasing concentrations from the center of arsenic contamination at the Site (see Figure 1 of
this support document).
Sample S34 was not identified as a background sample in the HRS documentation record or used in determining a
background level because it was relatively close to samples with arsenic contamination, and had a higher arsenic
concentration than the next more distant sample. Samples S39 (25 mg/kg), S3 (28.3 mg/kg), and S23 (28.7
mg/kg), which are located between the AOC and sample S34, indicate elevated levels of arsenic contamination
(see Table 1 of this support document). As shown in Figure 1 of this support document, sample S34 is located
approximately % mile west of sample S39, S3, and S23 locations. Sample S35, the next farther distant sample
(approximately 1/5 mile west of sample S34), has a concentration of 9.7 mg/kg, as indicated on page 196 of the
2009 ESI Report (see Table 1 of this support document). This pattern of decreasing concentration with distance
indicates that sample S34 is not an appropriate background sample because it could still be influenced by the
release of arsenic from the Site source.
Regarding AMEC's comment that while the HRS documentation record states that sample S34 was "mistakenly
identified as a background sample" in the 2009 ESI Report, the 2009 ESI Report does not share the same concern
about the sample; Reference 11 of the HRS documentation record at proposal supports the statement that sample
S34 was mistakenly identified in the 2009 ESI Report. Even if it were true that the 2009 ESI Report does not
share the same concern about sample S34, the HRS evaluation is not required to reach the same conclusions as
previous reports; rather, it uses data from previous reports to assign an HRS score using HRS-specific criteria.
While sample S34 is referenced in the HRS documentation record at proposal on page 21, as being "mistakenly
identified as background sample" in the 2009 ESI Report, the author of the 2009 ESI Report, Timothy Johnson,
submitted an affidavit (Reference 11 of the HRS documentation record at proposal) which states:
On page 11 of the ESI 2,1 erroneously identified sample S34 (ME2QX7) as a background sample
on a sample summary table for the site. Sample S34 was not collected as a background sample...
Sample S34 was collected as a step out sample because of the high levels of arsenic displayed in
samples S39, and S3/S23...
This affidavit statement is consistent with sample S34 being identified as a "step out" sample and not as a
background sample in the HRS documentation record at proposal.
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This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.6.4 Rationale for Not Using Sample S33 as Background
Comment: AMEC commented that background sample S33 was "rejected" in the HRS documentation record for
use in assigning a background level because it was considered to be "too close to the site." However, AMEC
noted that the HRS documentation record did not reject sample S34 based on the proximity of this sample
location to the Site.
Response: It is correct that sample S33 was not used as a background sample because of its location being close to
the Site. At the time of the sampling event, the extent of contamination had not been determined and because
sample S33 was "close to the site" it was not originally chosen as a background location. Neither sample S33 nor
sample S34 was used to establish a background arsenic level for identifying observed contamination at the Site in
the HRS evaluation. The rationale for not using sample S33 (i.e., proximity to the Site) is consistent with the
rationale and decision to not use sample S34 to establish a background level (sample S34 was considered a "step
out" sample as explained below in this section). In fact, both rationales reflect that the distance of the sample
location from the center of arsenic contamination is the reason that they were not selected as representative
background samples. Additionally, even if sample S33 were used as a background sample, there would be no
change in the established background level.
Page 21 of the HRS documentation record at proposal provides the rationale for excluding samples S33 and S34
as background samples:
Surface soil sample S34 was mistakenly identified as background sample in 2009 ESI 2 Report
(Refs. 5, p. 18; 11, p. 1). The initially designated background soil sample S33 appears to be much
closer to the AOC and therefore, is also not considered as a background sample.
As explained in section 3.6.3, Rationale for Not Using Sample S34 as Background, of this support document,
sample S34 was not included as a background sample due to elevated levels of arsenic in nearby samples. The
location of sample S34 was sufficiently close to site-related contamination to not be representative of background
conditions (i.e., concentrations absent the release from the Site). Therefore, although not specifically stated in the
HRS documentation record, sample S34 was not considered a background sample due to its proximity to the Site
contamination, which is consistent with the reasoning for the exclusion of sample S33 from being a background
sample.
While the rationale in the HRS documentation record for not including sample S33 is that sample S33 was located
"too close to the site," sample S33 is not associated with "step out" samples that extend from the center of the
arsenic contamination to sample S33 (see Figure lof this support document). Sample S35 has "step out" samples
S34, S39, S3, and S23 between the center of the arsenic contamination and the background samples that help to
indicate where the boundary of the site-related contamination is located. Because of the lack of "step out" samples
to help indicate the boundary of the site-related contamination and where a background sample should be taken,
sample S33 was not specifically identified as a background sample for use in establishing a background level.
However, even if sample S3 3 were used as a background sample for the HRS evaluation, the background level of
arsenic would remain unchanged. The arsenic concentration in sample S33 was 7.8 mg/kg (see Figure land Table
1 of this support document); this concentration is below the highest background concentration (9.7 mg/kg in
samples S35 and S36) used to establish the background level in the HRS evaluation. Thus, if sample S33 were
evaluated as a background sample in the HRS documentation record, it would not alter the background level
established. As explained above in section 3.6.2, Rationale for Not Using the ESI Background Level, of this
support document, the highest arsenic concentration found in a background sample was selected as the
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background level to ensure that the resulting release sample concentrations meet the significant increase criteria of
the HRS.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.6.5 Adequacy of Background Locations
Comment: AMEC commented that there are background samples in all quadrants except the southwest direction
and the HRS documentation record does not contain an explanation for this exception.
Response: The HRS evaluation appropriately selected background sample locations to determine a background
level for arsenic for use in establishing that a significant increase in arsenic levels occurred at the Site and to
screen out alternative sources that could be contributing to the significant increase in arsenic contamination at the
Site. It is not necessary at this site to have background samples located in each (compass) quadrant to establish
attribution.
As quoted in section 3.6, Establishment of Background Levels, of this support document, the HRS only states that
to establish observed contamination (or observed releases), the release concentration must be at least three times
greater than the background concentration (see HRS Table 2.3).
However, because the background level is used to show that a significant increase has occurred in contaminant
concentration based on the magnitude of the difference in the contaminant levels due to the release from a site, the
background samples are collected from locations outside the influence of the site. Further, the background
samples should be located between any other known non-site sources of the same contaminants and the site.
Contaminant levels in these samples would screen for contamination coming from these other sites.
The HRS documentation record states that background sample locations were chosen to be representative of
background conditions. Page 19 of the HRS documentation record at proposal states:
The background soil samples for this investigation were collected from the residential properties
away from Beck's Lake (Ref. 5, p. 18). .. .These locations were chosen to represent background
conditions because: (1) the soil type at the background sample locations are similar to the soil
types at the locations of samples collected from Area of Observed Contamination (AOC) A; (2)
theses sampling locations are at a distance away from Beck's Lake and appear to be
minimally affected by operations at Beck's Lake; (3) samples were collected within same time
period (October 5 and 6, 2009), therefore, under the same weather conditions; (4) samples were
collected at the same depth of 0 to 6-inches; (5) samples were collected by the same sampling
team and samples were collected in accordance with the approved Work Plan (Refs. 5, p. 18; 12,
pp. 1-19; 13, pp. 1-14). [emphasis added]
The HRS evaluation appropriately selected background sample locations to determine a background level and
screen out alternative sources. As explained previously in sections 3.6.2, Rationale for Not Using the ESI
Background Level, and 3.6.3, Rationale for Not Using Sample S34 as Background, of this support document,
samples S31, S32, S35, S36, and S37 were selected as background samples for the HRS evaluation because their
locations were the most distant from the center of the highest arsenic contamination (see Figure 1 of this support
document). Sample S33 (located in the southwest quadrant) was not identified as a background sample. This is
because the sample is located slightly nearer to the center of arsenic contamination than other background sample
locations and because no "step out" samples are associated with the sample location to show that the sample is
located outside of the influence from the Site. However, the arsenic concentration identified in sample S3 3 (7.8
mg/kg) is lower than the selected background level (see Table 1 of this support document), indicating that it is
outside of the influence of the release from the Site.
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December 2013
Additionally, sample S33 results support that there does not appear to be another source of arsenic in the
southwest quadrant contributing to the arsenic contamination at the Site. In fact, no alternative source of arsenic is
known to be located in the southwest quadrant, and AMEC did not identify any alternative arsenic sources in the
vicinity of the Site. If a source of arsenic were present in the southwest quadrant, the arsenic level in S3 3 would
be expected to be higher than in other areas where no source is known. As discussed above, the arsenic
concentration of 7.8 mg/kg in sample S33 is lower than in other background locations in other directional
quadrants, such as background samples S35 (9.7 mg/kg), S37 (7.9 mg/kg) and S36 (9.7 mg/kg) (see Table 1 of
this support document).
Therefore, the chosen background sample locations were properly used to establish a background level and screen
out alternative sources of arsenic that could be contributing to the Site contamination. Furthermore, as noted
previously, if sample S33 were used as a background sample, it would not impact the background level for the
Site.
This comment results in no change to the HRS score and no change in decision to place the Site on the NPL.
3.6.6 Consistency of Background Sample Concentrations with the National Background
Levels
Comment: AMEC commented that a 1984 United States Geological Survey (USGS) report depicts a range of
arsenic background levels throughout the United States as ranging from 1 mg/kg to 29 mg/kg, and AMEC stated
that S34 reasonably falls within this range of background values.
Response: Although AMEC provided no specific citation to the 1984 USGS report it discussed in its comments,
AMEC is most likely referring to the Shacklette and Boerngen 1984 USGS Professional Paper titled, Element
Concentrations in Soils and Other Surficial Materials of the Conterminous United States (1984 USGS paper;
Attachment 2 to this support document). The background level of 9.7 mg/kg used in the Beck's Lake HRS
evaluation is more consistent with the information in the 1984 USGS paper than the arsenic concentration
identified in sample S34 (12.9 mg/kg). Therefore, the data presented in the USGS paper provides support for the
EPA's decision to use a background level of 9.7 mg/kg. The arsenic data presented in the 1984 USGS paper
supports a regional background concentration level below the level identified in sample S34 (12.9 mg/kg).
In the 1984 USGS paper, samples located nearest to the Beck's Lake site, as well as the site-specific background
samples collected in the 2009 ESI Report, show that site-specific natural levels of arsenic in soils are lower than
that observed in sample S34. The 1984 USGS paper provides a table on page 6 that summarizes the mean
concentrations and ranges of elements in soil samples that were collected across the country. This table (Table 2
of the 1984 USGS paper) is divided into three categories: Conterminous United States, Western United States,
and Eastern United States. This report depicts a range of arsenic levels throughout the Conterminous U.S. (Table
2 of the 1984 USGS paper states that arsenic concentrations in the U.S. range from <0.1 to 97 parts per million6
[ppm] as opposed to ranging from 1 to 29 ppm as cited by AMEC). In addition, this table states that the geometric
mean concentration for arsenic east of the 96th meridian (Eastern United States) is 4.8 ppm with an estimated
arithmetic mean of 7.4 ppm; both of these values are below the background level for the Beck's Lake site of 9.7
mg/kg established in the HRS evaluation.
6 The 1984 USGS paper used different reporting methods and analysis than the 2009 ESI Report. The 1984 USGS paper
provides concentrations in |ig/g whereas the 2009 ESI Report provides concentrations in mg/kg. However, both of these are
reported in parts per million and thus are comparable.
17

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Beck's Lake NPL Listing Support Document
December 2013
In addition to Table 2 of the 1984 USGS paper, Figure 4 on pages 18 and 19 of the paper show all of the locations
of the samples collected across the United States and the concentration of arsenic found at each location. This
figure shows that the closest sample taken to the Beck's Lake site contains 4.1 ppm arsenic (with nearby
concentrations ranging from <0.1 to 6.5 ppm arsenic). The selected background level of 9.7 mg/kg arsenic is
actually closer to this value located nearest to the site in Figure 4 of the USGS paper (4.1 ppm) and to the national
arithmetic mean value of arsenic for the Eastern United States (7.4 ppm) than the value of 12.9 mg/kg found in
sample S34.
Overall, while the 1984 USGS paper indicates that there is a large range of natural arsenic concentrations
throughout the United States, the paper suggests that regional natural levels of arsenic near the Beck's Lake site
are possibly lower than the site-specific background level of 9.7 mg/kg established in the HRS evaluation.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.6.7 Presentation of Analysis to Support the Calculation of Background Levels
Comment: AMEC commented that there was no statistical evaluation presented in the HRS documentation record
or in the 2009 ESI Report that supported the calculation of the background levels. AMEC concluded that there
was "no statistical basis to reject S34 as a background sample."
Response: The background levels used in the HRS documentation record were correctly calculated consistent
with the HRS as presented in the HRS documentation record at proposal. As established in section 3.5,
Consistency with Guidance, of this support document, the HRS is a screening tool that uses limited sampling data;
therefore, the HRS does not require that a statistical analysis be performed as part of an HRS evaluation of the soil
exposure pathway. The HRS does not require a statistical analysis to be performed to establish the presence of
observed contamination or to determine background samples or background levels, instead it requires a specific
magnitude of increase in contaminant levels over background level to demonstrate a release.
As discussed in section 3.6.3, Rationale for Not Using Sample S34 as Background, of this support document,
sample S34 was never intended as a background sample for the Site as part of the HRS evaluation and was not
rejected as a background sample based on a statistical analysis. Sample S34 is located near sample locations that
contain elevated arsenic concentrations. Sample S34 contains a higher arsenic concentration than a more distant
sample (S35) in the same direction, and this demonstrates decreasing arsenic concentration as the distance from
the center of arsenic contamination increases. Thus it was considered that arsenic contamination in sample S34
may represent contamination from the Site and may not be representative of background conditions.
Instead of applying a statistical analysis to establish observed contamination, which includes the use of a
background concentration, the HRS uses the requirements of Table 2.3 of the HRS to show that a significant
increase in contamination levels between background and release samples has occurred. This procedure was
contained in the HRS when it was promulgated in 1990 (55 FR 51589, December 14, 1990), and its validity is
outside the scope of this rulemaking.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
18

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Beck's Lake NPL Listing Support Document
December 2013
4. Conclusion
The original HRS score for this site was 50.00. Based on the above responses to comments, the Site score remains
unchanged. The final scores for the Beck's Lake site are:
Ground Water
Surface Water
Soil Exposure
Air
HRS Site Score
Not Scored
Not Scored
100.00
Not Scored
50.00
19

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Attachment 1
Documentation of AMEC Freedom of Information Act (FOIA)
request

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FOIA - Freedom of Information Act
Page 1 of 1
Custom Report
One item found.
EPA-R5-
2013-007584
One item found.
Results
25 H
Custom Report - 08/01/2013 03:05:43
Tracking Number	Type :• Requester
' Steven
Submitted
Assigned
To
Task : D.
06/24/2013
Murray
Noreen
Weimer
Due
07/23/2013
Status
I Detail
Closed
Note: Requester Organization is available upon export.
https://foiaonline.regulations.gov/foia/action/agency/report/customRestilts
8/1/2013

-------

-------
FOIA - Freedom of Information Act
Page 1 of 3
Request Status : Closed Task Due Date ; 07/23/2013
Submitted
Evaluation
Assignment
Processing
Request Details
007584
D. Murray
Closed
Tracking Number; EPA-R5-
2013-
Requester: Mr.
Steven
06/21/2013
07/23/2013
Drive
Organization ; AMEC
Environment and
Infrastructure
Requester Has Account: No
Email Address :	_
06/24/2013
steven.d.murray@amec.com
Phone Number: 231-922-
9050
Fax Number: 231-922-
9055
Address: 41
Hughes
City: Traverse
City
State/Province : Ml
Zip Code/Postal Code : 49696
Request Type : FOIA
Request Track : Simple
Submitted Date ;
Due Date ;
Assigned To : Anna
Rzeznik
(Region 5)
Last Assigned Date :
Last Assigned By : Joseph
Winfrey
(Region 5)
Fee Limit: $25.00
Task Details					
Task Type: Request	Assigned To : Noreen
Detail	Weimer
Due Date :	(Superfund Division)
07/23/2013	Last Assigned Date :
https://foiaonline.reguktions.gov/foia/action/agency/task/detail7taslddHPJBPpO_pbZe6clN... 8/1/2013

-------
FOIA - Freedom of Information Act
Page 2 of 3
Description : Beck's 06/24/2013
Lake Site
located in South Bend,
Indiana
Comments: NW 7/22/13
Last Assigned By : Evette
Jones
(Superfund Division)
Submission Details
Review
Case File Admin Cost Assigned Tasks Comments
Request Handling	
Requester Info Available to the Yes
Public :
Request Track : Simple
Fee Category :
Commercial
Fee Waiver Requested: No
Fee Waiver Status: N/A
Expedited Processing Requested : No
Expedited Processing Status :	N/A
Request Perfected : Yes
Perfected Date :
06/24/2013
Acknowledgement Sent Date:
Unusual Circumstances ? No
Request Description
Short Description : Beck's Lake Site located in South Bend, Indiana
Description Available to the Yes
Public :
Has Request Been Modified?
Attached Supporting Files
Attachments Available to the Yes
Public :
https://foiaonline.reguIations.gov/foia/action/agency/task/detail7taskIcNPJBPpO pbZe6clN... 8/1/2013

-------
FOIA - Freedom of Information Act
Attached File
Steven, d. m array, pdf
Page 3 of 3
Type
! PDF
Size (MB)
0.12
https://foiaonline.regulations.gov/foia/action/agency/task/detail?taskId=PJBPpO_pbZe6clN... 8/1/2013

-------

-------
FOIA - Freedom of Information Act
Page 1 of3
Task Details
Request Status : Closed Task Due Date : 07/23/2013
Submitted
Evaluation
Assignment
Processing
Request Details
007584
D. Murray
Tracking Number
Requester
Closed
EPA-R5-
2013-
Mr.
Steven
Drive
06/21/2013
07/23/2013
Organization : AMEC
Environment and
Infrastructure
Requester Has Account: No .
Email Address:	„
06/24/2013
steven.d.murray@amec.com
Phone Number: 231-922-
9050
Fax Number: 231-922-
9055
Address : 41
Hughes
City
State/Province
Traverse
City
Ml
Zip Code/Postal Code : 49696
Request Type: FOIA
Request Track: Simple
Submitted Date ;
Due Date :
Assigned To : Anna
Rzeznik
(Region 5)
Last Assigned Date :
Last Assigned By : Joseph
Winfrey
(Region 5)
Fee Limit: $25.00
Task Details	
Task Type: Request	Assigned To : Noreen
Detail	Weimer
Due Date :	(Superfund Division)
07/23/2013	Last Assigned Date :
https://foiaonline.regulations.gov/foia/action/agency/task/deteil?taskId=:PJBPpO_pbZe6clN... 8/1/2013

-------
FOIA - Freedom of Information Act
Page 2 of 3
Description : Beck's 06/24/2013
Lake Site
located in South Bend,
Indiana
Comments : NW 7/22/13
Last Assigned By : Evette
Jones
(Superfund Division)
Submission Details
Review
Case File Admin Cost Assigned Tasks Comments
Request Handling
Requester Info Available to the Yes
Public :
Request Track ; Simple
Fee Category :
Commercial
Fee Waiver Requested*. No
Fee Waiver Status: N/A
Expedited Processing Requested : No
Expedited Processing Status : N/A
Request Perfected : Yes
Perfected Date :
06/24/2013
Acknowledgement Sent Date:
Unusual Circumstances ? No
Request Description
Short Description : Beck's Lake Site located in South Bend, Indiana
Description Available to the Yes
Public :
Has Request Been Modified? 11
Attached Supporting Files
Attachments Available to the Yes
Public :
https://foiaQnline.regulations.gov/foia/action/ageney/task/detail7taskIcHPJBPpO pbZe6clN... 8/1/2013

-------
FOIA - Freedom of Information Act
Attached File
Steven.d.murray.pdf
Page 3 of 3
Type
PDF
Size (MB)
0.12
https://foiaonline.regidations.gov/foia/ action/agency/task/detail?taskId=P JBPpO_pbZe6clN... 8/1/2013

-------

-------
June 21,2013
VIA E-MAIL AND UNITED STATES
MAIL
Freedom of Information Officer
U.S. EPA Region 5 (MI-9J)
77 West Jackson Blvd.
Chicago, IL 60604-3590
r5foia@epa.gov
Re: FOIA Request for Documents Related to Beck's Lake Site, South
Bend, Indiana
Dear FOIA Officer:
Under the Freedom of Information Act, 5 U.S.C. § 552,1 am requesting copies
of the following documents relating to the Beck's Lake Site, South Bend, IN, EPA ID
No. IND980904379 ("Beck's Lake Site"), docket number HPA-HQ-SFUND-2013-
1096:
•	Any and all tables of contents or indices of the Headquarters or Regional
Superfund Docket for the Beck's Lake Site.
•	Any work plans, sampling maps, sampling results and reports of
sampling results relating to sampling conducted on or about June 12 and
June 1,2013 in the vicinity of LaSalle Park and/or Beck's Lake or the
residential properties located on or near Falcon Street, west of LaSalle
Park, South Bend, IN.
•	Any and all maps or graphical depictions of locations sampled and
reported in the Beck's Lake Site Reassessment Inspection (August
2009).
•	Any and all maps or graphical depictions of locations sampled as
reported in the Hazard Ranking System (HRS) Documentation Record
Cover Sheet (May 2013).
•	Pollution Control Systems Inc., 1982, Analytical Results to Mr. Gerald J.
Budzin of Bendix, dated February 15, 1982, identified as reference
number 7 in the HRS Documentation record Cover Sheet (May 2013).
•	IDEM, Reassessment Report for LaSalle Park/Beck's Lake, South Bend,
Indiana, March 9, 2007, identified as reference number 10 in the HRS
Documentation record Cover Sheet (May 2013).

-------
June 21, 2013
Page 2
•	IDEM, Affidavit prepared by Timothy Johnson, State Cleanup Section,
IDEM, October 29,2012, identified as reference number 11 in the I IRS
Documentation record Cover Sheet (May 2013).
•	IDEM, Sampling Work Plan for Expanded Site Assessment prepared by
Tim Johnson of IDEM, October 1, 2009, identified as reference number
12 in the HRS Documentation record Cover Sheet (May 2013),
•	IDEM, Affidavit prepared by Timothy Johnson, IDEM, February 19,
2013, identified as reference number 13a in the HRS Documentation
record Cover Sheet (May 2013),
•	IDEM, Arsenic Concentration Map for Beck's Lake, South Bend,
Indiana, prepared by Kim Vcdder, January 12, 2010, identified as
reference number 14 in the HRS Documentation record Cover Sheet
(May 2013).
•	Weston Solutions Inc., Percent Moisture Calculations performed by
Omprakash S. Patel, January 25, 2013, identified as reference number 17
in the HRS Documentation record Cover Sheet (May 2013).
•	Weston Solutions Inc., Sample Quantitation Limit Calculations
performed by Omprakash S. Patel, January 25,2013, identified as
reference number 17A in the HRS Documentation record Cover Sheet
(May 2013).
•	Weston Solutions Inc., Map showing 200-foot radius distance from
sample locations S6, SB and S14, October 30, 2012, identified as
reference number 21 in the HRS Documentation record Cover Sheet
(May 2013).
•	IDEM., Letter from Mark Jaworski regarding addresses located on North
Falcon Street South Bend, Indiana, with 4-page attachment, identified as
reference number 27 in the HRS Documentation record Cover Sheet
(May 2013).
•	Toeroek Associates , Inc. Letter with attachments to Mike Rafati, U.S.
EPA Region 5, Subject: Title Search - Beck's Lake Site, Follow up
January 31, 2013, identified as reference number 28 in the HRS
Documentation record Cover Sheet (May 2013).
•	Weston Solutions Inc., Area Calculation for Source 1 performed by
Omprakash S. Patel, March 26, 2013, identified as reference number 29
in the HRS Documentation record Cover Sheet (May 2013).

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June 21, 2013
Page 3
Please provide me the documents responsive to this request in ail electronic format,
such as on CDs or DVDs.
Our fee category is commercial use. If there are any fees for searching or
copying the records, please provide an estimate of cost prior to releasing the records.
Please contact me as soon as possible with the estimated costs. If the scope of this
request is such that you expect unreasonable delay in processing it, please contact me
immediately to reach an agreement upon a schedule for responding in installments.
If you deny all or any part of this request, please cite each specific exemption
you think justifies your withholding of information. Please also notify me of appeal
procedures available under the law. Although a written reply is requested and expected,
if you have any questions about handling this request, you may telephone me at
231.922,9050 Ext. 208 or contact me by e-mail at Steven.D.MuiTay@amec.com.

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FOIA - Freedom of Information Act	Page 1 of 8
Task Details	Request Status : Closed Task Due Date : 07/23/2013
Submitted	Evaluation Assignment
Processing
Request Details
Closed
Tracking Number: EPA-R5-
2013-
007584
Requester: Mr.
Steven
D. Murray
Organization : AMEC
Environment and
Infrastructure
Requester Has Account: No
Task Details
Task Type: Request	Assigned To : Noreen
Detail	Weimer
(Superfund Division)
Submission Details Case File Admin Cost Assigned Tasks Comments
Review	
Direct URL:
https://foiaonline.regulations.gov:443/foia/action/public/view/request/80081224
[ Case Categorization and Initiation
https://foiaonline.regulations.gov/foia/action/agency/task/detail/caseFileRecords
8/1/2013

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FOIA - Freedom of Information Act
Page 2 of 8
Type of Case: FOIA
Fiscal Year : 2013
Total Days Pending : 19
Received Date
06/21/2013
Clock Initially Started On
06/24/2013
Closed Date
07/22/2013
Case Close Out Details-
Date Fees Paid :
Final Disposition : Pull grant
Records Consultations Correspondence Appeals invoice
Restricted Materials
Case Responsive Records
Filter by Title or Keyword(s) : 1
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8/1/2013

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FOIA - Freedom of Information Act
Page 3 of 8
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8/1/2013

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FOIA - Freedom of Information Act
Page 4 of 8
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8/1/2013

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FOIA - Freedom of Information Act
Page 5 of 8
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FOIA - Freedom of Information Act
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8/1/2013

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FOIA - Freedom of Information Act
Page 7 of 8
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FOIA - Freedom of Information Act
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8/1/2013

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EPA-R5-2013-007584
6/24/13 - Received FOIA
6/26/13 - Ran off SEMS and checked the documents responsive.
7/1/13 - Put in Retrieval to make sure everything is in SEMS, checking for 2013 documents
(form in file). Sent email to Mary Fulghrum with a copy of the FOIA and the SEMS list (email
in file).
7/8/13 - Sent email to Owen Thompson to find out if he had anything for Bullets 2-4 (email in
file). Received email from Owen that he got the test results in last week, need to check with
Mary to see if they are re leasable (email in file).
7/9/13 - Received email from Mary that we need to let the requestor know estimated amount of
money, would go over the $25.00 amount. Also she will look over the new sampling report from
Owen for bullet #2, bullet 3 she doesn't have any information but check for addresses and names
to be redacted (email in file).
7/10/13 - Received email from Owen that he will give the sampling data to Mary to look over to
see if releasable, had information for bullet #3 which I have and to check with site assessment for
bullets 3 and 4 (email in file).
7/11/13 - Sent email to Owen thanking him for the information and that #436629 I couldn't find
which was the IDEM ESI2 Report but that I found it on the SEMS list under #436689 which was
the IDEM Expanded Site Inspection 2 Report and that I will ask site assessment if they have
anything for bullets 3 and 4 (email in file). Sent email to Mary/Owen that I need an estimate
from them so I can let the requestor know an estimate amount (email in file). Forwarded the
email from Owen to Pat/Nuria/David and Erica, explained that both Nuria and Pat are out and if
they could help out or do they want me to wait until Pat gets back (email in file). Received
email from Mary that she has worked Vi already and may spend another Vz hour, for a total of 1
hour (email in file). Received email from Owen that the #436689 was the right document (email
in file). Received email from Owen that he has spent ¥z hour so far and probably spend another
Vi hour with Site Assessment People for a total of 1 hour (email in file). Sent email to the
requestor that the cost to respond would be over the $25.00 and gave him an estimate of $200.00
and that if it would happen to be more I would let him know (email in file). Received email
from the requestor giving the OK for the $200.00 fee commitment (email in file). Received
email from Erica and suggested that I give Document ID #'s 905138-905171 (email in file).
Sent email to Erica thanking her and asked for her time spent (email in file).
7/16/13 - Sent email to both Owen and Mary and let them know I have everything except for the
sampling data and to let me know if this is releasable or not (email in file). Received email from
Owen that he is sure it is releasable since they put it on the Beck's Lake EPA website (email in

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file). Sent email to Owen and Mary saying thanks and that I will put it in for scanning as
releasable (email in file). Put the sampling data that Owen sent with the email into the Records
Center to be scanned, once scanned then I can do the response.
7/18/13 — Jeff Doerr was calling for the requestor, the requestor was out of the office, he wanted
to know an update on the FOIA. I told Mr. Doerr that the letter was in the being put through the
process of reviewing the letter and that when it was done, I would upload the documents to our
system and the requestor would be getting an email with an Internet Link to receive the
documents. I also told him that the requestor gave a $200.00 fee commitment but it only eosted
$77.00.

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SRC-7J
Steven D. Murray
AMEC Environment and Infrastructure
41 Hughes Drive
Traverse City, Michigan 49696
Re: Freedom of Information Act
FOI Number: EPA-R5-2013-007584
Site(s): Beck's Lake Site, South Bend, Indiana
Dear Mr. Murray:
This letter serves as the Superfund Division's response to your Freedom of Information Act
(FOIA) request to the U. S. Environmental Protection Agency dated June 21, 2013.
The Superfund Division will be providing the responsive documents to your FOIA request
through the FOIA On-Line system. You will receive a final disposition notice from the
Region 5 FOIA Office that will provide you with an Internet link to access the disclosed
documents. An enclosed index of the responsive documents granted by the Superfund
Division is included with this letter.
You will receive an invoice from the Region 5 FOIA Office in the amount of $77.00 that
covers the cost of search, review, and any duplication of responsive documents. The charges
were confirmed on July 18, 2013.
Superfund public dockets and Administrative Records may be obtained at the Superfund
Record Center located at the EPA office in Room 714. The Record Center is open to the
public Monday through Friday 8:00 am to 4:00 pm.
You may appeal this response to the National Freedom of Information Officer, U.S. EPA,
FOIA and Privacy Branch,1200 Pennsylvania Avenue, N.W. (2822T), Washington, DC
20460 (U.S. Postal Service Only), FAX: (202) 566-2147, E-mail: hq.foia@epa.gov. Only
items mailed through the United States Postal Service may be delivered to 1200 Pennsylvania
Avenue, NW. If you are submitting your appeal via hand delivery, courier service or
overnight delivery, you must address your correspondence to 1301 Constitution Avenue,
N.W., Room 6416.1, Washington, DC 20004. Your appeal must be made in writing, and it

-------

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must be submitted no later than 30 calendar days from the date of this letter. The Agency will
not consider appeals received after the 30 calendar day limit. The appeal letter should include
the request number EPA-R5-2013-007584. For quickest possible handling, the appeal letter
and its envelope should be marked "Freedom of Information Act Appeal."
Should you have questions regarding your FOIA request, you may contact me at
(312) 353-8655. All other matters should be directed to Evette Jones, Chief, Enforcement
Services Section #3 at (312) 886-7572.
Sincerely,
Noreen Weimer
Freedom of Information Act Specialist
Enforcement Services Section #3
Superfund Division
Enclosures
cc:
Region 5 FOIA Office, MRI-9J
FOIA File

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DOCUMENTS TO THE REQUESTOR
Please see the attached document list for the record(s) that have been uploaded to our FOIA
Online System.

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Attachment 2
Element Concentrations in Soils and Other Surficial
Materials of the Conterminous United States, U. S.
Geological Survey Professional Paper 1270, Shacklette and
Boerngen, 1984

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Element Concentrations in Soils and
Other Surficial Materials of the
Conterminous United States
U.S. GEOLOGICAL SURVEY PROFESSIONAL PAPER 1270

-------
Element Concentrations in Soils and
Other Surficial Materials of the
Conterminous United States
By HANSFORD T. SHACKLETTE and JOSEPHINE G. BOERNGEN
U.S. GEOLOGICAL SURVEY PROFESSIONAL PAPER 1270
An account of the concentrations of
50 chemical elements in samples of
soils and other regoliths
UNITED STATES GOVERNMENT PRINTING OFFICE, WASHINGTON : 1984

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UNITED Sf Alls DEPARTMENT Of THE INTERIOR
WILLIAM P, CLARK, Secretary
GEOLOGICAL SURVEY
Dmllas L. Peck, Director
(Geological Survey professional piper ; 1270)
Bibliography: 105 p,
Supt. of Deeg. No.: IISUS
I. Soils—Unitrd Suu»--C<«np«iitK>n
L Boaracn AmpUteC. II. TW#. Ill
eij'tft
AACK
For sale by the Distribution Branch, U.S. Geological Survey,
604 South Pickett Street, Alexandria, VA 22304

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CONTENTS
Abstract 						1
Introduction . . , . 				1
Acknowledgments		 			 . , , 				2
Review of literature		 				2
Collection and mmlysai of geochemical data 			3
Sampling plan 					 				3
Sampling media			 .	S
Chemical-analysia procedure* , . . 					5
Data presentation					5
Diacuwwn of result* 		7
References cited 						9
ILLUSTRATIONS
Fko*E 1. Map showing location of umplmg rites in the contertmnou» United Stoles
where element* not commonly detected in Mrfiaal deposits were found,
and the amounts of the elements present 				12
2-41. Map«	showing element content of eurficial materials in the owiterminou*
United State#;
2. Ahnraraim ................................	14
8.	Antimony		 						18
4.	Arsenic 					18
5.	Barium 					20
6.	Beryllium 			22
?. Boron						24
8.	Bromine .................................	26
9.	Calcium					28
10.	Carbon (total) 		80
11.	Cerium 					 			 ,	32
12.	Chromium					34
13.	Cobalt 							 .	36
14.	Copper 				 .	38
15.	Fluorine				40
16.	Gallium 								42
17.	Germanium 						44
18.	Iodine					46
19.	Iron							48
20.	Lanthanum . 				6#
21.	Lead				 					62
Lithium			64:
a.	Magnesium 					56
24.	Mangaaeae 					58
.25,	Mercury 						60
28.	Molybdenum 				62
27.	Neodytnium 			 						64
28.	Nickel						66
29.	Niobium 					§8
30.	Phosphorus 			70
31.	Potassium				72
32.	Rubidium 				74
38.	Scandium 					78
34.	Selenium 				78
35.	Silicon					80
88.	Sodium 			 					 .	82
III

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IV
CONTENTS
Figures 37 -47. Maps	showing element content of iwfctal m*t*nabi in the comerminou*
United Sutea:
87.	Strontium			»	84
88.	SttBw					»
39.	Thorium 					98
40.	Tin 					90
41.	Titanium 		.	K
42.	Uranium			 		 			M
43.	Vanadium 						§§
44.	Ytterbium					gg
45.	Yttrium							MO
49. Zinc 				102
47. Zirconium 			 				104
TABLES
Table 1. Average or median contents, and range in contents, reported for etemvnta in soils and other *urfi«al materials . . 4
8, Mean rtmcentrationi, deviation*, and ranges of elements in tampta of m>Ua airi other surfida! materials in the conterminous
ITmtod States . . 										i

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ELEMENT CONCENTRATIONS IN SOILS AND' OTHER
SURFICIAL MATERIALS OF THE
CONTERMINOUS UNITED STATES
By Hansford T. Shacklette and Josephine G. Bof.rnc,en
ABSTRACT
Samples of soils or other regoliths, taken at a depth of approxi-
mately 20 em from locations about 80 km apart throughout the conter-
minous United States, were analyzed for their content of elements.
In this manner, 1,318 sampling sites were chonen, and the results
of the sample analyses for 50 elements were plotted on maps. The
arithmetic and geometric mean, the geometric deviation, and a histog-
ram showing frequencies of analytical values are given for 47 ele-
ments.
The lower concentrations of some elements (notably, aluminum,
barium, calcium, magnesium, potassium, sodium, and strontium] in
most samples of surfltisl materials from the Eastern United States,
and the greater abundance of heavy metsda in the same materials
of the Western United States, indicates a regional geochemical pat-
tern of the largest scale. The low concentrations of many elements
in soils characterise the Atlantic Coastal Plain, Soils of the Pacific
Northwest generally have high concentrations of aluminum, cobalt,
iron, scandium, and vanadium, but arc low in boron. Soils of the
Rocky Mountain region tend to have high concentrations of capper,
lead, and zinc. High mercury concentrations in surffcial materials are
characteristic of Gulf Coast sampling sites and the Atlantic coast sites
of Connecticut, Massswhuette, and Maine. At the State level, Florida
has the most striking geochetnieal pattern by having soils that are
low in the concentrations of most element* considered in this study.
Some smaller patterns of element abundance can b
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2
ELEMENT CONCENTRATIONS IK SOILS, CONTERMINOUS UNITED STATES
dition&l samples) were analyzed for other elements, and
the results were published in U.S. Geological Survey
Circulars: for mercury, Shacklette, Boemgen, and
Turner (1971); for lithium and cadmium, by Shacklette,
and others (1973); and for selenium, fluorine, and arse-
nic, Shacklette and others (1974).
The collection of samples for this study continued,
as opportunities arose, until autumn 1975, resulting in
the sampling of an additional 355 sites that were
selected to give a more uniform geographical coverage
of the conterminous United States, This sampling con-
tinuation is referred to as phase two. These samples
were analyzed, and the data were merged with those
of the original samples to produce the results given in
the present report. In addition, the availability of
analytical methods for elements not included in the ear-
lier reports permitted data to be given on these ele-
ments in the more recently collected samples.
The collection localities and dates, sample descrip-
tions, and analytical values for each sample in the pre-
sent report were published by Boemgen and Shacklette
(1981). The elemental compositions of only the surficia!
materials are given in this report; the data on analyses
of the plant samples arc held in files of the U.S. Geolog-
ical Survey.
ACKNOWLEDGMENTS
This study was made possible by the cooperation of
many persons in the U.S. Geological Survey. We thank
D. F. Davidson, A. T. Miesch, J. J. Connor, R. J.
Ebens, and A, T. Myers for their interest in, and con-
tinued support of, this study. The sampling plan was
suggested by H. L, Cannon, who also contributed
analytical data from her project areas and samples from
her travel routes. Others of the Geological Survey who
collected samples, and to whom we express gratitude,
are: J. M. Bowles, F. A. Branson, R. A. Cadigan, F.
C. Canney, F. W. Cater, Jr., M. A. Chaffey, Todd
Church, J. J. Connor, D wight Crowder, R. J. Ebens,
J. A. Erdman, 6. L. Feder, G, B. Gott, W. R. Griffitts,
T. P. Hill, E. K. Jenne, M. I. Kaufman, J, R. Keith,
Frank Kleinhampl, A, T. Miesch, R, F, Miller, R. C.
Pearson, E, V. Post, Douglas Richman, R. C, Sever-
son, James Scott, D. A. Seeland, M. H. Staatz, T. A.
Steven, M. H. Strobell, V. E, Swanson, R. R. Tidball,
H. A. Tourtelot, J. D. Vine, and R. W. White. We
thank the following members of the U.S. Department
of Agriculture Soil Conservation Service for providing
soil samples from areas in Minnesota: D. D. Barron,
C. E. Carlson, D. E. DeMartelaire, R. R. Lewis,
Charles Sutton, and Paul Nyberg.
We acknowledge the analytical support provided by
the following U.S. Geological Survey chemists; Lowell
Artis, Philip Aruscavage, A. J, Bartel, S. D. Bot!
L. A. Bradley, J. W. Budinsky, Alice Caemmerer,
P. Cahill, E. Y. Campbell, G. W. Chloe. Don Ca
E. F. Cooley, N. M. Conklin, W, B. Crandell, Mauri
Dev alii ere, P. L. D. Elmore, E, J. Finlay, Johns
Gardner, J. L. Glenn, T. F, Harms, R. G. Haves
R. H. Heidel, M. B. Hinkle, Claude Huffman, Jr., I
B, Jenkins, R. J. Knight, B. W. Lanthorn, L. M. Ls
K. W. Leong, J. B. McHugh, J. D. Mensik, V. M. Ma
ritt, H. T. Millard, Jr., Wayne Mountjoy, H, 1
Nakagawa, H. G, Neiman, Uteana Oda, C. S. E, Pap)
R. L. Rahill, V. E, Shaw, G. D. Shipley, HezekiJ
Smith, A. J. Sutton, Jr., J. A. Thomas, Barbara Tebil
J. E. Troxel, J. H. Turner, and G. H VanSickle,
We were assisted in computer programming for th
data by the following persons of the U.S. Geologkt
Survey: W, A. Buehrer, G. I. Evenden, J. B. Fife
Allen Popiel, M. R. Roberts, W, C. Schomburg, G. I
Seiner, R. C. Terrazas, George Van Trump, Jr., mi
R, R. Wahl.
REVIEW OF LITERATURE
The literature on the chemical analysis of soils art
other snrfieial materials in the United States is exten-
sive and deals largely with specific agricultural prob
iems of regional interest. Many of the papers were writ-
ten by soil scientists and chemists associated with State
agricultural experiment stations and colleges of agriewl
tare, and most reports considered only elements th*
were known to be nutritive or toxic to plants or ant
mats.
Chemists with the U.S. Department of Agncultun
prepared most early reports of element abundance k
soils for large areas of the United States. (See Robin-
son, 1914; Robinson and others, 1917), The 1938 year-
book of agriculture was devoted to reports on soils of
the United States; in this book, McMurtrey and Robin-
son (1938) discussed the importance and abundance of
trace elements in soils. Amounts of the major elements
in soil samples from a few soil profiles distributed
throughout the United States were compiled by the soil
scientist C. F. Marbut (1935) to illustrate characteris-
tics of soil units.
The use of soil analysis in geoehemical prospecting
began in this country in the 1940's, and many reports
were published on the element amounts in soils from
areas where mineral deposits were known or suspected
to occur. Most of these reports included only a few ele-
ments in soils from small areas. This early geoehemical
work was discussed by Webb (1953) and by Hawkej
(1957). In succeeding years, as soil analyses became an
accepted method of prospecting and as analytical
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COLLECTION AND ANALYSIS OF GEOCHEMICAL DATA
3
methods were improved, many elements in soils were
analyzed; still, the areas studied were commonly small.
An estimate of the amounts of elements in average,
or normal, soils is useful in appraising the amounts of
elements in a soil sample as related to agricultural, min-
eral prospecting, environmental quality, and health and
disease investigations. Swaine (1955) gave an extensive
bibliography of trace-element reports on soils of the
world, and he also summarized reports of the average
amounts of elements as given by several investigators.
The most comprehensive list of average amounts of rare
and dispersed elements in soils is that of Vinogradov
(1959), who reported the analytical results of extensive
studies of soils in the Union of Soviet Socialist Repub-
lics, as well as analyses of soils from other countries.
He did not state the basis upon which he established
the average values; however, these values are presuma-
bly the arithmetic means of element amounts in samples
from throughout the world. In their discussions of the
principles of geochemistry, Goldachmidt (1954) and
Rankama and Sahama (1955) reported the amounts of
various elements present in soils and in other sarficial
materials, Hawks and Webb (1982) and, more recently,
Brooks (1972), Siegal (1974), Levinson (1974), and Rose
and others (1979) gave average amounts of certain ele-
ments in soils as useful guides in mineral exploration.
A report on the chemical characteristics of soils was
edited by Bear (1964). In this book, the chapter on
chemical composition of soils by Jackson (1964) and the
chapter on trace elements in soils by Mitchell (1964)
gave the ranges in values or the average amounts of
some soil elements.
Regional geochemical studies conducted by scientists
of the U.S. Geological Survey within the past two de-
cades have been largely directed to the establishment
of baseline abundances of elements in surfieial mate-
rials, including soils. Most of the earlier work investi-
gated these materials that occurred in their natural con-
dition, having little or no alterations that related to
human activities, with the objective of establishing nor-
mal element concentrations in the materials by which
anomalous concentrations, both natural or man induced,
could be judged. Some of these studies were conducted
in cooperation with medical investigators who were
searching for possible relationships of epidemiological
patterns to characteristics of the environment. In one
study, the geochemical characteristics of both natural
and cultivated soils were determined in two arms of
Georgia that had contrasting rates of cardiovascular dis-
eases (ShaekJette and others, 1970), In an extensive
geochemical study of Missouri, also conducted coopera-
tively with medical researchers, both cultivated and
natural soils were sampled. The results were presented
for the State as a whole, and for physiographic regions
or other subdivisions and smaller areas, as follows:
Erdman and others (1976a, 1976b); Tidball (1976,1083a,
1983b); and Ebens and others (1973). The results of
these studies, and of other regional geochemical investi-
gations, were summarized and tabulated by Connor and
ShaekJette (1975).
Recent regional studies of soil geochemistry by the
U.S. Geological Survey related to the development of
energy resources in the western part of the United
States, including North Dakota, South Dakota, Mon-
tana, Wyoming, Colorado, Utah, and New Mexico.
These studies established regional geochemical
baselines for soils, both in undisturbed areas and in
areas that had been altered by mining and related ac-
tivities. Some of these studies considered the elements
in soils both as total concentrations and as concentra-
tions that were available to plants of the region. The
results of these studies were published in annual prog-
ress reports (U.S. Geological Survey, 1974, 1975, 1976,
1977, and 1978). The data on soils, as well as on other
natural materials, in these reports were summarized
and tabulated by Ebens and ShaekJette (1981). In a
study of the elements in fruits and vegetables from 11
areas of commercial production in the United States,
and in the soils on which this produce grew, soils were
analyzed for 39 elements, as reported by Boerngen and
Shacklette (1980) and ShaekJette (1980),
The average amounts of elements in soils and other
surfieial materials of the United States, as determined
in the present study, are given in table 1, with the
average values or ranges in values that were reported
by Vinogradov (1959), Rose and others (1979), Jackson
(1964), Mitchell (1964), and Brooks (1972), The averages
from the present study given in table 1 are the arithme-
tic means. Although the averages were computed by
the methods described by Miesch (1967), the values ob-
tained are directly comparable with the arithmetic
means derived by common computational procedures,
COLLECTION AND ANALYSIS OF
GEOCHEMICAL DATA
SAMPLING PLAN
The sampling plan was designed with the emphasis
on practicality, in keeping with the expenditures of time
and funds available, and its variance from an ideal plan
has been recognized from the beginning. Because the
collection of most samples was, by necessity, incidental
to other duties of the samplers, the instructions for
sampling were simplified as much as possible, so that
sampling methods would be consistent within the wide
range of Mnds of sites to be sampled. The samples were
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4
ELEMENT CONCENTRATIONS IN SOILS, CONTERMINOUS UNITED STATES
Table 1.—Average or Motfisti content*, and range m content*, mperUdfirr ekmmls is toil* and other maficud imtmiaU
jjltefca m is parts p& nu&kon; ©sets *««**£<*	trftJhjriseik mm®; Jetdem (—) m «l«m» issdiaKfce m data available. A, avenge; M, roedssa. , greater than}
This report
Rose, and others
(3 979> <<*le»ents
useful In
prospecting)
Average
Range
Vinogradov
(1959)
(presumably,
averages f r«
worldwide
fi&oplfnx)
Mitchell (1964)
Brmks (197?)
Rattle in
contents In
Scottish sur-
face toil®
Average or
range
	—		
5
10
500
6

400 - 3,000
<5 - 5
-				
	


<2 - 00
10
5 - 3,000
<10 - 100
o o
} 5 - 70
10,000 - 50,000
20
Al-
A&-
B—
Br—-
C, total
Ca	
€«*--	
Co—	
Cr-—¦»--
Cu-—*
Fe	
72,000
7.2
31
580
.92
.85
15,000
24,000
75
9.1
54
25
430
26,000
17
700
<0,!
<20
SO
<1
<0. 5
600
too
<150
« •
1 •
<1
<10
100
<5
>.
-^0,000
• 300
-	5,000
-	15
-	it
-	370,000
-	120,000
-	300
-	70
-	2,000
-	700
-	3,700
-	>100,000
-	70
7-5 m
29 100,000
7.000
15
100,000
Hh	
11

<10
-
100
Nd ——
46

<70
-
300
Hi——
19

<5
-
700
P		
4 30

<20
-
6,800
Pb—~—
19

<10
-
700
Kb		
67

<20

230
S, total
1,600

<800

48,000
Sb	

.66
<1
-
s.a
Sc	—
0.
9
<5
-
so
S#*~

,39
<0.1
••
4.3
310,000 16,000 - 450,000
1.3
<0.1
-
10
240
<5
-
3,000
.900
70
«,
20,000
9.4
2,2

32
2.?
0.2?
_
n
80
<7
--
500
25
<10
-
200
3,1
<2
-
50
60
<5
-
2,900
230
<20
-
2,000
0.056 
3 3,000 <«}
.01
400 - 28,000
<30 - 200
6.2
(TO
320
00
2,5
(A)
15
(A)
17

100
- 2,000
2
(A)
>.3i
1,000
10
300
1
100
Authot'a usage; generally used to indicate the aoet c
ly occurring value.
collected by U.S. Geological Survey personnel along
their routes of travel to areas of other types of field
studies or within their project areas.
The locations of the routes that were sampled de-
pended on both the network of roads that existed and
the destinations of the samplers. Sampling intensity
was kept at a minimum by selecting only one sampling
site every 80 km (about 50 miles; selected for conveni-
ence because vehicle odometers were calibrated in
miles) along the routes. The specific sampling sites
were selected, insofar as possible, that had surficial ma-
terials that were very Bttle altered from their natural
condition and that supported native plants suitable for
sampling. In practice, this site selection necessitated
sampling away from readouts and fills. In some areas,
only cultivated fields and plants were available for sam-
pling.
Contamination of the sampling sites by vehicular
emissions was seemingly insignificant, even though
many sites were within 100 m or less of the roads. Col-
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letting samples at about 20 cm depth, rather than at
the upper soil horizons, may have avoided the effects
of surface contamination oa the samples. However, we
had no adequate way of measuring any contamination
that may haw occurred. (See Cannon and Bowles,
1962.) Many of the sampled routes had only light veh-
icular traffic,, and seme were new fafcerafcafc highways.
Routes through congested areas generally were not
sampled; therefore, bo gross contamination of the sam-
ples was expected.
Th»* study areas that were sampled follow: Wisconsin
and. parts of contiguous Slates, southeastern Missouri,
Georgia, and Kentucky, sampled by Shacklette; Ken-
tucky, sampled by J. J. Connor and R. R. Tidball;
Mevada, New Mexico, and Maryland, sampled by H.
L. Camion; various ioeatioma in Arizona, Colorado, Mon-
tana, New Mexico, Utah, and Wyoming, sampled by
F. A, Branson and R. F. Miller; Missouri, sampled by
Shacklette, J. A. Erdman, J. R. Keith, and R. R. fid-
ball; and various locations in Colorado, Idaho, Montana,
South Dakota, Utah, and Wyoming, sampled by A. T.
Miesch and J. J. Connor. Sampling techniques used in
these areas varied according to the primary objectives
of the staifi.es being conducted, but generally these
techniques were closely similar to the methods used in
sampling along the roads.
In general, the sampling within study areas was more
intensive than thai along the travel routes. To make
the sampling intensity of the two sampling programs
more nearly equal, only the samples from selected sites
in the study areas were used for this report. Th#
self cted sites were approximately 80 km apart. Where
two or more samples were collected from one site, they
were assigned numbers, and one of these samples was
randomly chosen for evaluation in this study.
SAMPLING MEDIA
The material sampled at most sites could be termed
"soil" because it was a mixture of comminuted rock and
organic matter, it supported orfiitsry land plants, and
it doubtless contained a rich nilcroMota, Some of the
sampled deposits, however, were not soils as defined
above, but were other kinds of rpgnliths. The regoliths
included desert sands, sand dune#, some loess deposits,
and beach and alluvial deposits that contained little or
no visible organic matter. In some places the distinc-
tions between soils and other regoliths are vague be-
cause the materials of the deposits are transitional be-
tween the two. Samples wi re collected from a few de-
posits consisting mostly of organic materials that would
ordinarily be classified as pat, rattier than soil
To unify sampling techniques, the samplers were
asked to collect the samples at a depth of approximately
20 cm below the surface of the deposits. This depth
IJfMTIOM	6
was chosen as our estimate of a depth below the plow
soue that would include parts of the zone of illiviation
in most well-developed zonal soils, and as a convenient
depth for sampling other surGcial materials. Where the
thickness of the material wa§ less than 20 cm, as ii
shallow soils over bedrock or in lithosote over large rock
fragments,, samples were taken of the material that lay
iust above the rock deposits. About 0.25 liter of this
material was collected, put in a kraft paper envelope,
mi shipped to the U.S. Geological Survey laberatories
in Denver, Colo.
CHEMICAL-ANALYSIS HtOCEDURES
The soil samples were oven dried in the laboratory
and then sifted through a 2-mm sieve. If the soil mate-
rial would not pass this sieve, the sample was pul-
verized in a ceramic mill before seiving. Finally, the
sifted, minus 2-mm fraction of the sample was used for
analysis.
The methods of analysis used for some elements were
changed during the course of this study, as new tech-
niques and instruments became available. For most ele-
ments, the results published in the first report
(Shacklette, Hamilton, and others, 1971) were obtained
by me of a semiquantitative six-step emission spec-
trographs method (Meyers and. others, 1961). The
methods used for other elements were: EDTA titration
for calcium; colorimetric (Ward and others, 1963) for
phosphorus and zinc; and flame phtftonaetrj for potassi-
um. Many of the elements analyzed in the 355 samples
collected in phase two of the study were also analyzed
by the emission spectrographs method (Neiman, 1976X
Other methods were used for the following elements:
flame atomic absorption (Huffman ami Dinnin, 1976) for
mercury, lithium, magnesium, sodium,, rubidium, and
zinc; lametess atomic absorption. (Vaughn, lit?) for
mercury; X-ray fluorescence spectrometry (Wahlberg,
1178} for calcium, germanium, iron, potassium., seleni-
um, silver, sulfur, and titanium; combustion (Huffinan
and Dinnin, 1976) for total carbon; and neutron activa-
tion (Millard, 1975, 1976) for thorium and uranium.
DATA PRESENTATION
Summary data for 48 elements are reported in tables
1 and 2. In table 1, the element concentrations found
in samples of soil and other surficial materials of this
study are compared with those in soils reported in other
studies. Arithmetic .memos are used for the data of this
study to make them more readily cempared with the
data geuefitDjr reported in the literature. These arith-
metic means were derive I from the estimated geomet-
ric means by using a technique described by Mtesefi
(1967), which is 'based on methods devised, by Oeheii
CliSf) and SieteJ (1962). The arithmetic means in table
-------
6
ELEMENT CONCENTRATIONS IN SOILS, CONTERMINOUS UNITED STATES
1, unlike the geometric means shown in table 2, are
estimates of geochemkai abundance (Mieseh, 1967).
Arithmetic means are always larger than corresponding
geometric means (Mieseh, 1967, p. Bl) and are esti-
mates ef the fractional part of a single specimen that
consists of the element of concern rather than of the
typical concentration of the element in a suite of sam-
ples.
Concentrations of 46 elements in samples of this
study are presented in table 2, which gives the determi-
nation ratios, geometric-mean concentrations and devia-
tions, and observed ranges in concentrations. The
analytical data for most elements as received from the
laboratories were transformed into logarithms because
of the tendency for elements in natural materials, par-
ticularly the trace elements, to have positively skewed
Table 2,—Afros ctmcenimtiom,	and range» of element* in samples of soils and other mrfmal mattmalt in th* conUrrminou*
United States
\M$mm r$m$m «u* reported m port* p«r mfllkn (Mfc), meaiw and dew&tiw. ve pmrmiwk exempt m indicated. Ratio, number of mm$m in wfeieb the* element wm found
in mea#rarab)« coiwfin'tretJw to noratar of aampks analysed. «, IHiss; >, greater tk&a)
Conterminous
l/nltnd Sr«Cf?«
Mean
Devi a
tion
Esticated
arithmetic
Western Unites! States
(wfsr of 96th meridian)
Estimated
Devi a- Observed arlthnetlc
tion	range	&©«
Eaatrrn United Scurea
(e«*t of 96th •aeridisu^
Estimated
Devla-	Observed arithmetic
t ion	range	*«an
41, percent
4.7
2,69
7.2
66 h 770
5.8
2.00
0.5
-
>10
7.4
450:477
3,3
2,87
0,7

>10
5.7
Ah"""-"*""'—
5,2
2.23
7.1
728;730
5.5
1.98
<0.10
...
97
7.0
521:52?
4.6
2.56
<0.1
-
73
7,4
i			
26
K$7
3?
506. 778
31
S.99
<20
--
300
29
425: 54*
31
1.88
<20
-
150
38
Ba			
440
2.14
580
778.778
580
1.72
70
-
5,000
670
541: 541
?<»0
2.35
10

1,500
420
Be--—	—
.63
2.38
.92
310:778
.68
2.30
<1
-
15
.97
169:525
,55
2.53
<1
-
7
.85
Br		
.56
2,50
,R5
111:220
.52
2.74
<0. 5
.
11
.86
78;128
,62
2.18
<0.5
.
5.3
.8"*
C, perc^rjt-
1.6
2.57
2.5
250:250
1.7
? 37
0.16
-
10
2.5
162:162
1.5
2.88
0.06
-
37
2.6
C,a» percent
,92
4.00
2.4
777:777
1,8
3.05
0.06
-
32
3.3
514:514
.34
3.08
0.01
-
28
.63
Ce	—
63
1.78
75
81:683
65
K 7 1
<150
-
3<>0
75
70:489
63
1.85
<150
-
300
76
Co		—
6.7
2.10
9.1
698:778
7.1
1.9?
O
"
50
9.0
403: 533
5.9
2.57
<0.3
-
70
9. 2
Cr	——
3?
2,37
54
778:778
41
2.19
3
-
2,0t>0
56
541:541
33
2.60
1
-
1 ,000
52
Cu		
17
2.44

778-. 778
21
2.07
2
-
300
27
523: 533
13
2.80
<1
-
700

P-—	
510
3.34
430
598; 6 W
280
2. 52
10
2,6
539: 540
1.4
2.87
0.01

>10
2. 5
G«			
13
2.03
17
767:776
16
1.68
<5
-
70
19
431:540
9.3
2.38
<5
-
70
14
C€——
1,2
1.37
1.2
224:224
t.2
1.32
0,58
.
2.5
1.2
130:131
U!
1,45
<0.1

2.0
1.2
Hg	
.ow
2,52
.089
729:733
,046
2.33
<0.01
-
4.6
.065
534:534
.081
2.52
0.01
_
3.4
.12
1		—
.n
2,63
1*2
{69:246
.79
2. 55
<0. 5
-
9,6
1.2
90:1 53
.68
2,8]
<0.5
-
7,0
1,2
K, percent'
1.5
,79
Hone
777:777
1.8
.71
0.29
-
6.3
None
537:537
1.2
!•?5
0.005
-
3.7


10
1.92
37
462:777
30
1,89
<30
-
200
37
294:516
29
1.98
<30
-
200
37
»«•¦»	•-»
20
1.85
24
731:735
22
1.58
5
_
130
25
479:52?
17
2.16
<5

140
22
percent
.44
3.28
.90
777:778
.74
2.2?
0.03
-
>10
1.0
52$:529
,23
3.55
Q.005

5
.46
M»		
330
2,77
550
777:777
360
1.93
30
-
S,00f>
480
537;540
260
1,82
<2
-
?,ono
640
Mo—	
.59
2.72
,97
57:774
.85
2. i?
<3
-
•»
1.1
32:524
.32
3,93
<3
-
15
.79
Kh, percent
• 59
3,27
1.2
744:744
,97
135
0,05
-
10
1.2
363:449
.25
4.55
<0,05
-

.78
KV-	—
*.3
1.75
11
418:771
8.7
1.82
<10
_
ion
10
322:498
10
1.65
<10
_
50
12
M	<		
40
1.68
46
120. 538
36
1.76
<70
-
300
43
109:332
46
1.58
<70
-
300
51
Hi——		
13
2.31
19
74 7:778
IS
2.10
<5
-
700
19
44 3 : 540
n
2.64
<5
-
700
18
—	- -
260
2,67
430
524:524
*20
2,33
40
-
4,500
460
380:382
200
2.95
<20
-
6,800
360
Ph	<	
16
£.86
19
712:778
1.7
3.80
<10
-
700
20
422:541
14
1.95
<10
"
300
17
Rh—¦—		—¦
58
! .72
67
221:224
69
1,50
<20
_
210
74
3 07;131
41
1.94
<20
_
160
53
S, percent-
,52
2,04

34:224
,13
3,17
<0.08
-
4.8
.19
20:131
. 30
2.34
<0.08
-
0.31
. 11
Sb			
.48
2.27
.67
35:223
,47
?.l 5
<1
-
2.6
.62
31:33}
.52
2.38
<1
-
8.8
.76
Sc—¦
7.5
1.82
8.9
685:778
8. 2
1.74
<5
-
50
9.6
389:526
6, 5
J .90
<5
-
30
8,0
S«.	——
.26
2.46
.39
590:733
.23
2.43
<0.1
-
4.3
,34
449: 534
.30
2.44
<0. 3
-
3.9
.45
Si, percent*
3i
6.48
Hone
250:250
30
5.70
15
-
44
None
156:156
34
6.64
1,7
...
45

$Tf
.89
2,36
1.3
218:224
.90
2.11
<0,1
..
7.4
1.2
123:131
,86
2.81
<0.1
-
10
; . 5
Sr		
120
3,30
no
778:778
m
2.16
10
-
3,000
270
501: 540
53
3.61
<5
-
700
1 20
Ti, partem
,24
1.89
.29
777:777
.22
1.78
0.05
._.
2.0
,26
540:540
.2B
2.00
0.007
-
1.5
.35
Th-	--
8,6
t„53
9.4
195:195
9.1
1.49
2.4
-
31
9,8
102: 102
7.7
1.58
2.2
-
23
8.6
y,	—		
2,3
1.73
2.7
224:224
2.5
1.45
0.68
«
7.9
2.7
130;130
2.1
2.12
0.29
_
11
2.7
V-*—		>—	-
58
2.25
80
778:778
70
1.95
7

500
88
516: 541
43
2.51
-------
DISCUSSION OF RESULTS
7
frequency distributions. For this reason, the geometric
mean is the more proper measure of central tendency
for these elements. The frequency distributions for po-
tassium and silicon, on the other hand, are more nearly
normal if the data are not transformed to logarithms
and the mean is expressed as the arithmetic average.
In geochemical background studies, the magnitude of
scatter to be expected around the mean is as important
as the mean. In lognormal distributions, the geometric
deviation measures this scatter, and this deviation may
be used to estimate the range of variation expected for
an element in the material being studied. About 68 per-
cent of the samples in a randomly selected suite should
fall within the limits MID and M-D, where J# repre-
sents the geometric mean and D the geometric devia-
tion, About 95 percent should fall between MiD? and
M-If, and about 99,7 percent between M/D* and Af-D3,
The analytical data for some elements include values
that are below, or above, the limits of numerical deter-
mination, and these values are expressed as less than
(<} or greater than {>) a stated value. These data are
said to be censored, and for these the mean was com-
puted by using a technique described by Cohen (1959)
and applied to geochemical studies by Mieseh (1%?).
This technique requires an adjustment of the summary
statistics computed for the noncensored part of the
data. The censoring may be so severe in certain sets
of data that a reliable adjustment cannot be made; with
the data sets used in the present study, however, no
such circumstances were encountered. The use of these
procedures in censored data to quantify the central ten-
dency may result in estimates of the mean that are
lower than the limit of determination. For example, in
table 2 the geometric-mean molybdenum concentration
in soils from the Eastern United States is estimated
to be 0.32 ppm, although the lower limit of determina-
tion of the analytical method that was used is 3 ppm.
Use of this procedure permits inclusion of the censored
values in the calculation of expected mean concentra-
tions,
The determination ratios in table 2—that is, the ratio
of the number of samples in which the element was
found in measurable concentrations to the total number
of samples—permit the number of censored values, if
any, to be found that were used in calculating the mean,
This number is found by subtracting the left value in
the ratio from the right.
The distribution of the sampling sites and the concen-
trations of elements determined for samples from the
sites are presented on maps of the conterminous United
States (figs. 1-47). Figure 1 shows the locations of sites
where four elements, bismuth, cadmium, praseodymi-
um, and silver, were found in the samples, These ele-
ments were determined too uncommonly for reliable
mean concentrations to be calculated. Each of the re-
maining maps (figs. 2-4?) gives the locations where an
element was found in a sample from a site and the con-
centration of the element, shown by a symbol that rep-
resents a class of values. By examining the tables of
frequency for concentration values of the elements, we
were able to divide the ranges of reported values for
many elements into five classes so that approximately
20 percent of the values fell into each class. The limited
range in values for some elements, however, prohibited
the use of more than two or three classes to represent
the total distribution, Symbols representing the classes
were drawn on the maps by an automatic plotter that
was guided by computer classification of the data, in-
cluding the latitude and longitude of the sampling sites.
A histogram on each map gives the frequency distribu-
tion of the analytical values, and the assignment of
analytical values to each class as represented by sym-
bols.
We were able to obtain analyses of 11 more elements
for the 356 samples of phase two of this study than
for the 963 samples of phase one because of improved
analytical methods and services. These elements are an-
timony, bromine, carbon, germanium, iodine, rubidium,
silicon, sulfur, thorium, tin, and uranium. The con-
straints of resources and time prohibited analysis of the
963 samples of the first phase for these additional ele-
ments. Results of -analysis of the plant samples that
were collected at all soil-sampling sites are not pre-
sented in this report.
Some elements were looked for in all samples but
were not found. These elements, analyzed by the
semiquantitative spectrograph^ method, and their ap-
proximate lower detection limits, in parts per million,
are as follows: gold, 20; hafnium, 100; indium, 10; plati-
num, 80; palladium, 1; rhenium, 30; tantalum, 200; tellu-
rium, 2,0CM); and thallium, 50. If lanthanum or cerium
were found in a sample, the following elements, with
their stated lower detection limits, were looked for in
the same sample but were not found: dysprosium, 50;
erbium, 50; gadolinium, 50; holmium, 20; lutetium, 30;
terbium, 300; and thulium, 20.
DISCUSSION OF RESULTS
The data presented in this report may reveal evi-
dence of regional variations in abundances of elements
in soils or other regoliths; single values or small clusters
of values on the maps may have little significance if
considered alone. Apparent differences in values shown
between certain sampling routes, such as some of those
across the Great Plains and the North Centra] States
where high values for cerium, cobalt, gallium, and lead
predominate, suggest the possibility of systematic er-
-------
8
ELEMENT CONCENTRATIONS IN SOILS, CONTERMINOUS UNITED STATES
rers in sampling or in laboratory analysis. Some gross
patterns and some of lesser scale, nevertheless, are evi-
dent in the compositional variation of regoliths, as
shown in figures 2^47,
The lower abundances of some elements (notably alu-
minum, barium, calcium, magnesium, potassium, sodi-
um, and strontium) in regoliths of the Eastern United
States, and the greater abundances of the heavy metals
in the same materials of the Western United States
indicate a regional pattern of the largest scale. This
visual observation of the maps can be substantiated by
examining the mean concentrations for these two re-
gions given in table 2. The abundances of these ele-
ments differ markedly on either side of a line extending
from western Minnesota southward through east-cen-
tral Texas. This line is generally from the 96th to 97th
meridian, and corresponds to the boundary proposed
by Mar but (1935, p, 14), which divides soils of the
United States into two major groups—the pedalfers
that lie to the east, and the pedocals to the west. Mar-
but (1928) attributed the major differences in chemical
and physical qualities of these two major groups to the
effects of climate on soils, A line approximating the 96th
meridian also separates the Orders, Suborders, and
Great Groups of moist-to-wet soils in the Hasten:
United States from the same categories of dry soils that
He to the west, as mapped by the [U.S.] Soil Conserva-
tion Service (1969). As shown in table 2. soils of the
Western United States have the highest mean values
for all elements considered in this report except for an-
timony, boron, bromine, mercury, neodymium, seleni-
um, titanium, and zirconium. The differences, however,
probably are not significant for these latter elements,
except for zirconium.
Superimposed upon this large-scale compositional
variation pattern are several features of intermediate
scale. Perhaps the most notable of these are the low
concentrations of many elements in soils of the Atlantic
Coastal Plain. Soils of the Pacific Northwest are high
in concentrations of aluminum, cobalt, iron, scandium,
and vanadium, but low in boron, and soils of the Rocky
Mountain region tend to be high in copper, lead, and
zinc.
Several small-scale patterns of compositional varia-
tion can be noted, among them the high mercury con-
centrations in surficial materials from the Gulf Coast
of eastern Texas, Louisiana, Mississippi, Alabama, and
northwest Florida, and a similar pattern on the Atlantic
Coast in Connecticut, Massachusetts, and Maine. High
phosphorus values occur in soils along a line extending
west across Utah and Nevada to the coast of California,
then south-east in California and Arizona, At the State
level, Florida shows the most striking pattern by hav-
ing low soil concentrations of most of the elements con-
sidered in this study.
The concentrations of certain elements do not show
well-defined patterns of distribution, and the regional
concentrations of some other elements cannot be
evaluated because they were not present in detectable
amounts in most of the samples, or because the sam-
pling density was insufficient. The degree of confidence
in regional patterns of element abundance is expected
to be in direct proportion to the number of samples
analyzed from the region. As the observed patterns be-
come smaller, the probability increases that the charac-
teristics that form the patterns are the results of
chance.
Some features of element-abundance patterns proba-
bly reflect geologic characteristics of the areas that the
soils overlie. Samples from most of the regoliths overly-
ing basic volcanic rocks of Washington and Oregon con-
tained higher than average concentrations of iron and
other elements, as mentioned earlier. A few soil sam-
ples with high phosphorus content are associated with
phosphate deposits in Florida, and a single sample in
Michigan with high copper content is known to be of
soil that occurs over a copper deposit.
These data do not provide obvious evidences of north-
south trends in elemental compositions that might be
expected to relate to differences in temperature re-
gimes under which the surficial materials developed.
There is, moreover, no consistent evidence of signifi-
cant differences in element abundances between
glaciated and nonglaciated areas (the general area of
continental glaciation includes the northern tier of
States from Montana to Maine and south in places to
about lat 40°N.; see fig. 1),
The world averages of abundance for some elements
in soils, as given by Vinogradov (1959) and by others
(table 1), do not correspond to the averages of abun-
dance for these elements in the soils of the United
States, according to the data presented in this report.
The world averages are too low for the concentrations
of boron, calcium, cerium, lead, magnesium, potassium,
and sodium in United States soils and other surficial
materials, and too high for beryllium, chromium, galli-
um, manganese, nickel, phosphorus, titanium, vanadi-
um, and yttrium.
The stability of values for concentrations of most ele-
ments seems to be satisfactory because the addition of
analytical values for 356 samples of phase two of the
study to values for 963 samples of the first phase did
not significantly change the geometric means and devia-
tions of element abundance that were reported earlier
(Shacklette, Boerngen, and Turner, 1971; Shacklette,
Hamilton, and others, 1971; Shacklette and others,
-------
1973, 1974). Although aAMtiomil sampling of the same
type as. reported here might give a clearer picture of
souLUhto-intermediate element-abundance patterns,
mean values reported herein most likely would not
diaage significantly,
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——1976b, Elemental composition «>f com grains, aoybean seed*,
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Mieicfc, A. T., Geodwmkal «ur»ey of Uuwmri—Metlioda ofsam
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Geological Survey Profeaokmal P«pr 9M-A, p. 12-14.
—		9
Jackson, M. L„ 19M, OMnnictl eomposition of mils, m Bear, F. E„
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Lew#**, A. A., 1974, Introduction to exploration geochemistry: Cal-
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—19ft, SoOb «f the United Statea. pt. 1 of Ate of Aj«®w«b
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in mineral exploration t2
-------
10	ELEMENT CONCENTRATIONS IN SOILS, CONTERMINOUS UNITED STATES
Unite! States: U.S. Geological Survey Circular 644, 6 p.
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7, p, 321-348.
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ELEMENT C*>NCEN TR ATlONfc IN SOILS rONTlSRMlNOUS UNITED STATES
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ELEMENT CONCENTRATIONS IN SOILS, CONTERMINOUS UNITED STATES
IU USTR&TlOSi>
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ELEMENT CONCENTRATIONS IN* 80H.8 OOXTEKMINOCH XtSITEli rATEh
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64
ELEMENT CONCENTRATIONS IN SOILS, OWTERMINOt'S UNITED STATES
ILLOWIAMOMS
66
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ELEMENT CONCENTRATIONS IN SOILS, CONTERMINOUS UNITED STATES
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ELEMENT CONCENTRATIONS IN SOILS, CONTERMINOUS UNITED STATES
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70
E US ME NT CONCENTRATIONS IN SOILS, (XWTKRMlNOt'S lINITFin STATES
tLLtlSTEAridNS
71
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ELEMENT CONCENTRATIONS INF SOILS, CONTERMINOUS UNITED STATES
ILLUSTRATIONS
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ELEMENT CONCENTRATIONS IN SOILS, t'ONTERMlNOrs UNITED STATES
ILUISTKATJONS
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ILLUSTRATIONS
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