74
INSTALLATION RESTORATION PROGRAM PRELIMINARY ASSESSMENT I t" *..128th Tactical Fighter Wing Wisconsin Air National Guard I Truax Field Madison, Wisconsin IDTIC i EFLECTEII I I HAZWRAP SUPPORT CONTRACTOR OFFCE Oak Ridge. Tennessee 37831 Operated by MARTIN MARIETTA ENERGY SYSTEMS. INC. For the U.S. DEPARTMENT OF ENERGY under contract DE-AC05-44OR21400 912 11 Obl,

*..128th Tactical Fighter Wing Wisconsin Air National Guard I … · 2011. 5. 15. · INSTALLATION RESTORATION PROGRAM PRELIMINARY ASSESSMENT I t" *..128th Tactical Fighter Wing Wisconsin

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Page 1: *..128th Tactical Fighter Wing Wisconsin Air National Guard I … · 2011. 5. 15. · INSTALLATION RESTORATION PROGRAM PRELIMINARY ASSESSMENT I t" *..128th Tactical Fighter Wing Wisconsin

INSTALLATION RESTORATION PROGRAM

PRELIMINARY ASSESSMENTI t"

*..128th Tactical Fighter WingWisconsin Air National Guard

I Truax FieldMadison, Wisconsin

IDTIC i EFLECTEII

I

I HAZWRAP SUPPORT CONTRACTOR OFFCEOak Ridge. Tennessee 37831

Operated by MARTIN MARIETTA ENERGY SYSTEMS. INC.For the U.S. DEPARTMENT OF ENERGY under contract DE-AC05-44OR21400

912 11 Obl,

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I

I-- / - ---- I 1 __ "N- __ [.t -l / < - /

iN VEN . -.. - _5.,1q li , 15--

127 _,fCEt-TR - -

---- 4

o~~ ~ ,OERO ¢, -. L,--.f --Z)r L

,--MIDDLET-

FXEChburg 14cMlN I

MADISON

Source: Official State Highway Map, Wisconsin Dept. of Transportation, 1986

This report has been prepared for the National Guard Breau, Washington, D.C.,

FII

by HAZWRAP Support Contractor' s office of Martin Marietta Enry Systems, Inc.,for the purpose of aiding in the inplemientation of the Air Force InstallationRestoration Program.

Copies of the final report may be purchased from:I

National Technical Information Service5285 Port Royal RoadISpringfield, Virginia 22161

Federal Govermet agencies and their contractors registered with the DefenseTechnical Information Center should direct requests for copies of this reportto:

Defense Technical Information CenterI

Cameron StationAlexandria, Virginia 22314

I

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Form Aporovea

REPORT DOCUMENTATION PAGE OMB No 0704-0188

Puelic recortin ouroen 1ot miis colitecti O ot

information is estimated to averacie I hour per resonse. nciuaing the time tor reviewlnq instructions, searcriing existing data sources.qatlperid and m aintaininq the data needed, and comoletino and reviewino t e collection of intormation. Send comments renaroirg this burden estimate Of any other aspect Of thiscoiecon -r -!ormatiOri ncuailnq Suggestions 'or -duciro thss ourcen ic .. asindton meadduarters ,ervices, Orectorate ior intornation Ocierations and aeocris. ih 15 jetferson

, , .24A,natOn. ja 22202-4302.and to tre Otffi-e ,7, Manarement and 9ucqet. 04oerwor Redluction Priect (07C4-0188). Wasn'inton .DC r503.

1. AGENCY USE ONLY (Leave biank) 2. REPORT DATE 3. BEPORT TYPE AND DATES COVERED

I . n -f- I re / ;5 ,-f C. , " ,

4. TITLE AND SUBTITLE -'Ret1rcxcg^ ? ,-'-fcrst' 5. FUNDING NUMBERS

-' .\ r ' t,- N- * .

6. AUTHORS)

7. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES) 8. PERFORMING ORGANIZATION

?E 0ono4 C0 Au// - -) ' . REPORT NUMBER

6? oot( 2 s'- urnps pkaCcsKr, e-, 7C nne , e & F3 0

9. SPONSORING/ MONITORING AGENCY NAME(S) AND ADDRESS(ES) 10. SPONSORING i MONITORING

S ,.-"\ -C" AGENCY REPORT NUMBER

11. SUPPLEMENTARY NOTES

12a. DISTRIBUTION /AVAILABILITY STATEMENT 12b. DISTRIBUTION CODE

4pruc gr jF ixhitc. r/e

13. ABSTRACT (Maximum 200 words)

14. SUBJECT TERMS r-.i . - 15. NUMBER OF PAGES

U) 1.0 4C1 4

ar 3.I . k&-+icir l 6 uarl 16. PRICE CODE

17. SECURITY CLASSIFICATION 18. SECURITY CLASSIFICATION 19. SECURITY CLASSIFICATION 20. LIMITATION OF ABSTRACTOF REPORT OF THIS PAGE OF ABSTRACT

NSN 75 0-01-280-5500 S-anoaro orm :98 (Rev 2-89)P'escroed v , AN',SIo 0 9-18

298-102

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III

INSAIMOK RESTORATIN PRGRAMPRELIMINARY ASSSSM1T'

I HEAD7ARERS, 128TH TACrICAL FTGc1I!WI

TH]A F=DMADIScN, WISNSIN

IAugust 1988

IPrepared for

National Guard BureauAndrews Air Fore Bas, Maryland 20331-6008I

Prepared by

EConsultants, P.C.575 Oak Ridge lNmMike

Oak Ridge, Tennessee 37830

IInteragency Agen No. 1489-1489-Al

III

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TABLE OF CONTENTS

Bae

.EC.IT.E RY ............................ vii

I. INITWDUCTION . . .1

A. Background .I-i .........t................................................-B. Purpose. .. .. ............ ............. 1-5

C. Scope ..................... .............. I-5

D. Methodology .......... .......................... . .1-6

II. INSTALIATION DESCRIPTION ........ ..................... I-i

A. Location .......... ........................... I-i

B. Organization and History .i. . . ..............- i

III. ENVIRNMENTAL SETTING ....... ...................... .II-I

A. Meteorology ......... ......................... I-I

B. Geology .................... ....... II-i

C. Hydrology .......... .......................... .. 111-8

D. Critical Habitats/Endangered or Threatened Species ....... III-10

n IV. SITE EVALUATION .......... ............................ IV-i

A. Activity Review ......... .......................... IV-I

B. Disposal/Spill Site Identification, Evaluation, andHazard Assessment ......... ........................ IV-I

c. Other Pertinent Facts ........ ..................... .. IV-7

V. CONCLUSIONS ........... ............................ .. V-I

VI. FEOMMENDATIONS .......................... V-I

Iiii

I

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TABLE OF OONTrNTSI(ccntine)

GLOSSARY OF TERS. .. .. .. ...... . ....... . ... . .... G-1

BIBIL1~Ao.PY . .. .. .. ...... . .... . . . . .. .. .. .. .. Bi-1

APPENDIX A - List of Undergrounl Storage Tanks. .. .. .. ......... A-1

APPENDIX B,-Resumes of Search Team Me±,ers. .. .. ... . ...... B-1IAPPENDIX C- Outside Agexicy Concact List .. .. .. .. . .......... C-1

APPENDIX D - USAF Hazard Assessment Rating Methodology .. .. .. ...... D-1

ivI

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ILIST OF FI(JRES

I IA. Preliminary Assessment Methodology FlMwdlart .......... 1-7

IIA. Location Map, 128th TFW, Wisconsin ANG, Truax Field, Madison,SWisconsin . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! -I icni.............................................. II-2

IIIA. Geologic Cross-Section .I. . . . . ............. ... 111-3

IIIB. Thickness of Glacial Drift ....... .................... . .111-4

IIIC. Bedrock Units Below Glacial Drift ...... ................ . .111-5

IIID. Soil Series Map of 128th TFW, Wisconsin ANG, Truax Field,Madison, Wisconsin ....... .. ........................ . I.111-6

IIIE. Surface Drainage System ...... ... .................... . .111-9

IVA. Location of Sites 1, 2, and 3 ......... .......... IV-5

LIST OF TABLES

Table

IVA. Hazardous Materials/Hazardous Waste Disposal Summary:128th TFW, Wisconsin ANG, Truax Field, Madison, Wisconsin ....... IV-2

IVB. List of Building Numbers, Building Names, and Street Addresses,128th TFW, Wisconsin ANG, Truax Field, Madison, Wisconsin ....... IV-4

Acoession For

NTIS GRA&Y~DTIC TAB 0Unannounced 13i Justification

ByDistribution/

Dist Special

I

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I

A. I XTflQI

PEER Consultants, P.C., was retained by the Hazardous Waste Remedial Actions

Program (HAZWRAP) Support Contractor Office in January 1988 to conduct an

Installation Restoration Program (IRP) Preliminary Assessment of the 128th

Tactical Fighter Wing (TFW), Wisconsin Air National Guard, Truax Field,

Madison, Wisconsin [hereinafter referred to as the Air National Guard Base

(ANGB) or the Base], under Contract No. IE-AC05-84OR21400. The Preliminary

.Assessment included:

o an on-site visit, including interviews with 19 ANGB employees

conducted by PEER personnel January 18-22, 1988;

0 the acquisition and analysis of pertinent information and records on

past hazardous materials use and past hazardous wastes generation and

disposal at the ANGB;

0 the acquisition and analysis of available geologic, hydrologic,meteorologic, and envirormental data from pertinent federal, state,

and local agencies; and

o the identification of potential sites on the ANGB that may be

contaminated with hazardous materials/hazardous wastes.

B. M JcR FNDGS

The major operations of the 128th TFW that have used and disposed of hazardous

materials/hazardous wastes include aircraft maintenance, ground vehicle

maintenance, aerospace ground equipment, and fire department training. The

operations involve such activities as corrosion control, nondestructive

inspection, fuel cell maintenance, and engine maintenance. Varying quantitiesof waste oils, recovered fuels, spent cleaners, strippers, and solvents were

generated and disposed of by these activities.

vii

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I

Interviews with 19 ANGB personnel having an average of 24 years' experience Ieach, analysis of pertinent information and records, and a field survey

resulted in the identification of three potential disposal/spill/storage sites

on the ANGB. The identified sites are as follows: Io Site No. 1 - JP-4 Fuel Spill No. 1 (unrated)o Site No. 2 - JP-4 Fuel Spill No. 2 (unrated)I

o Site No. 3 - PCB Spill (unrated)

C. OO SICNS I

After careful evaluation, the three identified sites have been considered to Ihave no significant potential for contamination and/or migration anA pose no

significant threat to the environment and public health.

D. RECXM19LTIRSI

Based upon the findings of this report, it is recmmended that the three

identified potential disposal/spill/storage sites be deleted from further IRP

evaluation. The implementation of Decision Documents based on the findings of

this report are recommended for the three sites to delete them from further IIRP evaluation. I

IiIII

viii iI

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I. ]NJCAUX IIQI

A.

The 128th Tactical Fighter Wing (TFW), Wisconsin Air National Guard (ANG), is

located at the Dane County Regional Airport/Truax Field, Madison, Wisconsin.The ANG Base (ANGB) has been in service since 1942 and over the years the typesI )f military aircraft based and serviced there have varied. Both past andpresent operations have involved use of hazardous materials and disposal ofhazardous wastes. Because of the use of hazardous materials and disposal ofhazardous wastes, the ANG has implemented its Installation Restoration ProgramI (IRP).

THE INSTALIATION RESIORATION PROGRAM

The Department of Defense (DoD) IRP is a corprehensive program designed to:Io Identify and fully evaluate suspected problems associated with pastIhazardous waste disposal and/or spill sites on DoD installations, and

o Control hazards to human health, welfare, and the environment that mayhave resulted from these past practices.

IDuring June 1980, DoD issued a Defense Environmental Quality Program Policy

Memorandum (DEQPPM 80-6) requiring identification of past hazardous waste1disposal sites on DoD installations. The policy was issued in response to theResource Conservation and Recovery Act of 1976 (RCRA) and in anticipation ofI the Ccmprehensive Environmental Response, Compensation and Liability Act of

1980 (CERCLA, Public law 96-510) cumonly known as "Superfund." In August

1981, the President delegated certain authority specified under CERCIA to the

Secretary of Defense via Executive Order (EO 12316). As a result of EO 12316,DoD revised the IRP by issuing DEQPPM 81-5 on December 11, 1981, which reissuedand amplified all previous directives and memoranda.

I-1

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m

Althxugh the DoD IRP and the USEPA Superfund programs were essentially the

same, differences in the definition of program phases and lines of authority

resulted in some confusion between DoD and state/federal regulatory agencies.

These difficulties were rectified via passage of the Superfund Amendments and

Reauthorization Act (SARA, PL-99-499) of 1986. On January 23, 1987,

Presidential Executive Order ED 12580 was issued. EO 12580 effectively revoked

EO 12316 and inplemented the changes promulgated by SARA.

The most unportant changes effected by SARA included the following:

o Section 120 of SARA provides that federal facilities, including those in

DoD, are subject to all the provisions of CERCLA/SARA concerning site

assessment, evaluation under the National Contingency Plan (NCP) [40 CFR

300], listing on the National Priorities List (NPL), and

remrval/remedial actions. DOD must therefore comply with all the

procedural and substantive requirements (guidelines, rules, regulations,

and criteria) promulgated by the USEPA under Superfund authority.

o Section 211 of SARA also provides continuing statutory authority for DoD 3to conduct its IRP as part of the Defense Environmental Restoration

Program (DERP). This was accomplished by adding Chapter 160, Sections

2701-2707 to Title 10 United States Code (10 USC 160).

o SARA also stipulated that terminology used to describe or otherwise midentify actions carried out under the IRP shall be substantially the

same as the terminology of the regulations and guidelines issued by the

USEPA under their Superfund authority.

As a result of SARA, the operational activities of the IRP are currently

defined and described as follows:

mI

I

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Preliminary Assessment (PA)

The PA is a records search designed to identify and evaluate past disposal

and/or spill sites which might pose a potential and/or actual hazard to public

health, welfare, or the envirorment.

Site Investigation/Remedial Investigation/Feasibility Study (SI/RI/FS)

The SI consists of field activities designed to confirm the presence or absence

of contamination at the sites identified as a result of the PA. The RI

consists of field activities designed to quantify the types and extent of

contamination present, including migration pathways.

If applicable, a public health evaluation is performed to analyze the collected

data. Field tests are required which may necessitate the installation of

monitoring wells and/or the collection and analysis of water, soil, and/or

sediment samples. Careful documentation and quality control procedures, in

accordance with CERCIU/SARA guidelines, ensure the validity of data.

Hydrogeologic studies are conducted to determine the underlying strata,

groundwater flow rates, and direction of contamination migration. The findings

from these studies result in the selection of one or more of the following

options:

o No further action - Investigations do not indicate harmful levels of

contamination and do not pose a significant threat to human health or

the environment. The site does not warrant further IRP action and a

decision document will be prepared to close out the site.

o Long-term monitoring - Evaluations do not detect sufficient

contamination to justify costly remedial actions. Long-term monitoring

may be reccumended to detect the possibility of future problems.

o Feasibility Study - Investigations confirm the presence of contamination

that may pose a threat to human health and/or the environment, and some

form of remedial action is indicated. The FS is therefore designed ana

1-3

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m

developed to identify and select the most appropriate remedial action.

The FS may include individual sites, groups of sites, or all sites on an

installation. Remedial alternatives are chosen according to engineering

and cost feasibility, state/federal regulatory requirements, public

health effects, and environmental impacts. The end result of the FS is

the selection of the most appropriate remedial action by the ANG with

concurrence by state aid/or federal regulatory agencies.

Remedial Design/Remedial Action (RD/RA)

The RD involves formulation and approval of the engineering designs required

to implement the selected remedial action. RA is the actual implementation of

the remedial alternative. It refers to the accomplishment of measures to

eliminate the hazard or, at a minimn, reduce it to an acceptable limit.

Covering a landfill with an impermeable cap, pumping and treating contaminated

groundwater, installing a new water distribution system, and in situ

biodegradation of contaminated soils are examples of remedial measures that

might be selected. In some cases, after the RAs have been completed, a long-

term monitoring system may be installed as a precautionary measure to detect many contaminant migration or to document the efficiency of remediation. IResearch and Development (R&D)

R&D activities are not always applicable for an IRP site, but may be necessary

if there is a requirement for additional research and development of control

measures. R&D tasks may be initiated for sites that cannot be characterized

or controlled through the application of currently available, proven

technology. It can also, in some instances, be used for sites deemed suitable mfor evaluating new technologies. IImmediate Action Alternatives IAt any point, it may be determined that a former waste disposal site poses an

immediate threat to public health or the environment, thus necessitating prompt

removal of the contaminant. Immediate actions, such as limiting access to the

1-4

I

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I

I site, capping or removing contaminated soils and/or providing an alternate

water supply may suffice as effectiva control measures. Sites requiring

i inmediate removal action maintain IRP status in order to determine the need for

additional remedial planning or long-term monitoring. Removal measures or

other appropriate remedial actions may be implemented during any phase of an

IRP project.

B. PURPOSE

I The purpose of the PA is to identify and evaluate suspected problems associated

with past hazardous wastes handling procedures, disposal sites, and spill sites

on the ANGB and to assess the potential for the migration of hazardous

contaminants. PEER Consultants, P.C., visited the ANGB, reviewed existingenvironmental information, analyzed the ANGB records concerning the use and

generation of hazardous materials/hazardous wastes, and conducted interviews

with past and present ANGB personnel who were familiar with past hazardous

materials management activities. Relevant information collected and analyzed

as a part of the PA included the history of the ANGB, with special emphasis on

the history of the shop operations and their past hazardous

materials/hazardous wastes management procedures; the local geological,

hydrological, and meteorological conditions that may affect migration of

contaminants; local land use, public utilities, and zoning requirements that

affect the potentiality for exposure to contaminants, and the ecological

settings that indicate environmentally sensitive habitats or evidence of

environmental stress.

C. SCDPE

The scope of this PA is limited to the property situated within the boundaries

of Pd property which is or has been controlled by the ANGB and included thefollowing:I

0 An on-site visit;

o the acquisition of pertinent information and records on hazardous

materials use and past hazardous wastes generation and disposal

1-5

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ipractices at the ANGB in order to establish the source and

characteristics of hazardous wastes or spills;

o the acquisition of available geologic, hydrologic, meteorologic, land iuse and zoning, critical habitat and utility data from various federal,

state, and local agencies in order to establish potential pathways and ireceptors of hazardous wastes or spills; i

o a review and analysis of all information obtained; and

o the preparation of a report, to include recommendations for further

actions.

The on-site visit, interviews with past and present personnel, and meetings

with local agency personnel were conducted during January 18-22, 1988. The IPEER PA team consisted of the following individuals (resumes are included as

Appendix B): I

o Mr. Tan Webb, Senior Project Manager 3o Mr. Anthony Wagner, Geologist

o Mr. Kevin Pack, Civil/Environmental Engineer

Individuals from the ANGB who assisted in the Preliminary Assessment include

(XSgt Ray Steinich, Facility Manager, and selected members of the 128th TFW. iThe Headquarters Air National Guard Support Center (ANGSC) Project Officer for

Truax Field ANGB was Mr. Hank Lowman of ANGSC/DER.

D. ME)OODDIDGY

A flowchart of the PA methodology is presented in Figure IA. This PA

methodology ensures, to the greatest extent possible, a comprehensive

collection and review of pertinent site-specific information, and is used in

the identification and assessment of potentially contaminated hazardous wastes ispill/disposal sites.

1-6

I

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I RECORDS SEORCH/INTERVIENS

CONLFTEI LIST OF LOCATIO$IS/SITES

VALUATION OF FAST OPERATIONS

PPOTETNTIFO

1 ~- DELETE SITES REFETIA TOOAS

IIR

CONSOLIDATESPECIFICSITE DATA

DECISION IAPPY AIR FORCEDOCUNENT HAZARD RATING

NJNERIC*L

SITE RATING

CONICLUJSIONS

I FIGURE IA. PRELIMINARY ASSESSMENT METHODOLOGY FLOWCM4RI,128th TFW, WISCONSIN ANG, TRUAX FIELD, MADISON, WISCONSIN

* 1-7

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nThe PA began with a site visit to the ANGB to identify all shop operations or

activities that may have used hazardous materials or generated hazardous

wastes. Next, an evaluation of past and present hazardous materials/hazardous

wastes hardling procedures at the identified locations was made to determine

whether environmental contamination may have occurred. The evaluation of past

hazardous materials/hazardous wastes handling practices was facilitated by

extensive interviews with 19 past ard present employees familiar with the

various operating procedures at the ANGB. These interviews were also

used to define the areas on the ANGB where any waste materials, either

intentionally or inadvertently, may have been used, spilled, stored, disposed

of, or released into the environment in order to establish the source and

characteristics of hazardous wastes or spills. 3Historical records contained in the ANGB files were collected and reviewed to Isupplement the information obtained fran interviews. Using the information

outlined above, a list of potential waste spill/disposal/storage sites on the

ANGB was identifiod for further evaluation. A general survey tour of the

potential sites, the ANGB, and the surroundin area was conducted to determine

the possible presence of visible contamination and to help the PEER survey team i

assess the potential for contaminant migration. Particular attention was given

to locating nearby drainage ditches, surface water bodies, residences, and

wells in order to establish potential pathways of the hazardous wastes or

spills.

Detailed geological, hydrological, meteorological, developmental (land use and

zoning), and environmental data for the area of study were also obtained from

appropriate federal, state and local agencies as identified in Appendix C for

the purpose of establishing receptors of hazardous waste or spills.

Using the process shown in Figure IA, a decision was then made, based on all

the above information, regarding the possibility for hazardous materials

contamination at any of the potential sites. If no potential for contamination

existed, a decision document was inplenented in order to delete the site from

further consideration. If potential for contamination was identified, the

potential for migration of the contaminant was assessed based on site-specific 3I-8

I

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cxrditions. If there was potential for cntamination migration, the site was

evaluated usinq the Hazard Asesn Rating Methodology (HARe). A discussion3 of the HAR4 system is presented in Apni D.

IIIIIII

II-

Ii

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III. I1EShUTIQ I31=IV

A. IW CMN

The 128th Tactical Fighter Wing is located at Dane Qmty Regional

Airport/Truax Field, approximately five miles northeast of downtown Madison,Wisconsin. The ANGB occupies approximately 155 acres of the original 2050

acres that the Department of Army acquired by 1943. Figure IIA shows thelocation and boundaries of the ANGB.

B. CFWNIZATICN AND EIS"IR

Truax Field became operational in October 1942. Its purpose was to train

radio operators and technicians for the Army Air Force. The city of Madison

had built a flying field on lands used as Truax Field before Department of

Defense involvement. The site consisted of approximately 1800 acres and

contained 856 teuporary and semi-permanent structures, which aco dted

45,000 troops and trainees. At the end of World War II, the city of Madison

assumed control of the Base from the War Assets Administration.

On October 6, 1948, an Air Guard organization at Truax Field was federally

recognized as the 176th Fighter Squadron, Wisconsin Air National Guard, with

several supporting units. Captain Arthur C. Smith was the active organizer of

the Madison units during that time.

By December 1948, the state of Wisconsin had been authorized by the National

Guard Bureau to negotiate with North Ontral Airlines for leasing of part of

the floor and hangar space at Truax Field. A lease was signed in January 1949,

and the Air National Guard and North Central Airlines acocmm:,dated each other

due to mutual lack of equip*ent and facilities. At this time F-51 "Emutangs,"

a C-47 (Gooney Bird), and a B-26 (Invader) were assigned to the flying units.

During 1949, contracts ware let for the construction of new facilities to

house the Air Guard at Truax Field, including an aircraft maintenance hangar,

base suply building, and a motor pool. The hangar still functions as the

II-I

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I N SCALE: 1"1=800,

BASE BOUNDARY

-,DOI

IFI

Fit IA. LOCATION MAP128th TFW

A~uwm srWISCON4SIN AIR NATION~AL GUARD_ J UX FIL

_______________________________________ WISMSfl4

11-23

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maintenance hangar, while the base supply building now houses the Cosolidated

Base Prsonnel Office, the Addnistration Office, the Base Omptroller, and

others. The original motor pool is no ocwpied by the Aerospace Groundi n shop.

The 176th Fighter Squadron was recalled as a unit to active duty in February

1951, due to the Korean Conflict. After the first =onth of active duty, all

units of the Wisconsin Air National Guard, both Madison and Milwaukee, were

stationed at Truax Field. In February 1952, the first major change within the

fighter squadron took place with the assignent of the F-89A Scorpion as the

primary aircraft. The 176th was one of the first units to becme all-weather

proficient during the Korean Conflict. The period of active duty lasted until

October 1952.

After returning to state status, the 176th reverted to one of the newer models

of the World War II F-51 fighters. A short tire later, the unit was equipped

with F-86A "aircraft." By 1954, F-89s replaced the F-86s.

In 1956 the Air Guard was reorganized as the 128th Air Defense Wing with its

headquarters at Truax Field. Newer models of the F-89, with nuclear

capabilities, soon replaced the older models.

The Air Guard's runway alert program was begun in 1961. F-102 "Delta Daggers"

replaced the F-89s in 1966. With the advent of the F-102s, regular Air Forceunits at Truax Field were being phased out. Only a detadment of Air Force

people were to remain at Truax Field, and their mission was to operate a

dispersal base. By June 1970, the Air Force had completely left Truax Field.

During this *hasedown, all unused buildings and land were turned over to the

city of Madison.

In 1974, with the phaseout of the air defense program, the 128th Air DefenseWing wms converted to the 128th Tactical Air Support Wing and began flying O-2A

forward air control aircraft and A-37s.

11-3

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IFinally, in 1981, the Air Guard unit was ocieze to the 128th Tactical

Fighter Win ard began flyiz A-10 airrf. The servic2 status of the 128thhas rxot d ns si-ie 1981.I

IIIIUIIIIIIIII

II-4I

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III. I

A. MEPWTHOIDGY

Rainfall in Dane County, Wisconsin, averages 30.8 inches annually and snowfall

averages 40.8 inches annually, based on the 30-year interval, 1951 to 1980. By

calculating net precipitation according to the method outlined in the Federal

Register (47 FR 31224, July 16, 1982), a net precipitation value of 0.8 inches

per year is obtained. The maximum rainfall intensity, based on a 1-year

frequency, 24-hour duration rainfall, is 2.25 inches (calculated according to

47 FR 31235, July 16, 1982, Figure 8).

B. GEODLGY

1. Regional Geology

Truax Field ANGB is located adjacent to the Dane County Regional

Airport/Truax Field at Madison, Wisconsin. The area is situated near

the geographic center of the Central Lowlands Physiographic Province

which encompasses a large portion of the central United States from

western New York State to the central portions of North and South

Dakota and as far south as northern Kentucky and northern Texas.

The Central Lowlands Province is characterized by mostly Paleozoic

bedrock with some Cretaceous rocks underlying the western boundary.

Much of this province also exhibits flat to gently inclined rock

strata and widespread topographic effects of glaciation.

Structurally, numerous domes and uplifts control regional dips. With

the exception of the south border, the entire province is bounded by

topography that is higher in elevation.

2. Local Geology

Truax Field ANGB proper lies near the western margin of the GreatLakes Section of the Central Lowlands Province. This section is

II -

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Icharacterized by numerous lakes with associated lacustrine plains,

prominent end moraines, poorly integrated drainage, and a still

partially exposed cuestaform topography. Lakes Mendota to the

southwest and Monona and Waubesa to the south of Truax Field

exemlify this region. The ANGB is predominantly on level ground

with drainage provided by man-made ditches into surrounding marsh Iareas. IThe ANGB is considered to occupy an ancient river valley, probably

the ancestral Yahara, which now lies about three miles to thenorthwest of the ANGB. Figure IIIA depicts a cross-sectional area

from Lake Monona northward to the present-day Yahara River about 2

miles west of Truax Field ANGB. By projecting the ANGB into the

cross section, one can see that the ANGB is situated over a very

thick section of drift. This buried valley is filled with Iapproximately 300 feet of glacial material (mostly sand and silt with

some clay and gravel). The ancient Yahara River most likely flowed

southwest into Lake Mendota. Figure IIIB shows the thickness of

glacial drift in the area of Truax Field ANGB. One can see that the

ANGB overlies the central portion of a thick wedge of drift. The

axis of this drift trends northeast-southwest. It is believed that

this is the path of the ancestral Yahara River.

Figure IIIC shows the bedrock units beneath the glacial drift. The nMount Simon Sandstone, Cambrian in age, lies under the drift section

at Truax Field ANGB and is about 300 feet thick.

3. Soils

The soils present at Truax Field ANGB are represented by three series

as defined by the U. S. Department of Agriculture Soil Conservation

Service (Figure IIID). The Wacousta Series covers the northern one-

half of the ANGB. This series consists of very poorly drained soils Iformed in silty sediments in depressions. The surface layer of the

Wacousta Series is a black silty clay loam, approximately 14 inches

111-2

I

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so NOR ?

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H.1 &ON a

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111-4I

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Is MO.L"3i"

IISE

I 2.V71

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I

Site No. 1 - JP-4 FUe1 Spill No. 1 (unrated) IFour 50,000 gallon underground storage tanks (USTs) (No. 405-1, -2, -3, and -4)

are located next to Building 405, the Petroleum, Oil, and Lubricant (POL) Pump

House. These tanks are constructed of cathodically protected steel and have

been in active use since 1952, the date of their installation. The tanks

currently contain JP-4 (jet fuel) used to refuel the aircraft on base. No

wastes are associated with this facility (see Appendix A).

On March 6, 1981, approximately 2,000 gallons of JP-4 spilled onto the ground

when one of the 50,000 gallon USTs overflowed during a loading operation.

Reportedly, an existing drainage ditch (about 100 feet long) next to the spillwas dammied off. The fire department foamed the fuel and also flushed the fuel

to direct it toward the ditch. The fuel soaked into the soil and was covered

with straw. (Refer to Sections III.B and III.C for soil permeability and

groundwater depth.) By April 9, 1981, as directed by the Madison area

Department of Natural Resources, the affected soil was removed to a depth of

about 6 feet in the ditch, or to the limit of odor detection on the ditch side

slopes. The material was then spread at 6 to 10 inches depth on four concrete

pads (used for mobile homes) that were located on what is now the parking lot

west of Building 500. The contaminated soil was turned during the following

summer to enhance volatilization. The next summer, 1982, the area was

excavated to a depth of at least 3 feet for a parking lot. The concrete pads

and contaminated soil were removed along with the excavated material and hauled

off base, and the area was asphalted the same year. Because of the corrective

measures taken to control contamination, the potential for additional

contamination is minimal.

Site No. 2 - JP-4 Fuel Spill No. 2 (unrated)

On August 3, 1985, approximately 100 gallons of JP-4 spilled onto the ground

due to a broken pipe on a transfer cart while loading used JP-4 into a waste

oil storage tank (No. 1201-1, see Appendix A). All fuel was contained by

diking and blotted up with absorbent blotters. The terrain in the area was

IV-6

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flat and the area was not adjacent to a body of water. Three 55 gallon drums

of contaminated earth were removed within 2 days of the incident. Because of

the corrective measures taken to control contamination, the potential for

additional contamination is minimal.

U Site No. 3 - PCB Sill (unrated)

Three pole-mounted transformers in an outdoor electrical training station were

located next to and east of Building 1201. In 1983, one of the units was

leaking dielectric fluid onto the ground approximately 4 feet below. The PCB

concentration in the leaking fluid was tested and determined to be 1800 ppm.

The qround area affected by the leak amounted to approximately 3 square feet.

Soil samples were taken in and around the spill area; the test results

indicated PCB levels from 0.3 to 31.6 ppm. A total of three 55 gallon drums

of PCB-contaminated soil were removed and the area was retested for PCB

contamination. The transformers were also removed to prevent further

contamination. After removal, tests indicated background levels at less than

0.1 ppm. Because of the corrective measures taken to control contamination,

the potential for additional contamination is minimal.

C. OINER PERTINE r FACTS

o The wash rack area, outside and adjacent to the Main Hangar (Building 400)and Aircraft Shelter (Building 412), was used to wash aircraft until about

1983. From 1983 to the present time, washing has been conducted inside the

Aircraft Shelter and occasionally inside the Main Hangar.

o During the site visitation to the Motor Pool and AGE, an apparent waste oil

residue was observed on the ground around the filling ports of the

associated USTs (see Appendix A). Reportedly, the residue was the result

of minor spillage during filling and removing (pumping) of waste oils.

There are no additional reported spills or leaks associated with these

USTs.

o An abandoned fuel pipeline system and fueling/defueling hydrant system are

located at the ANGB (see Appendix A). The fuel pipeline extends from an

IV-7

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Iabandoned tank farm (outside of the ANGB) to four 50,000 gallon USTs, next

to the Petroleum, Oil, and Lubrication (POL) Pump House. The hydrant

system line extends frm the Pump House to a series of filter meter pits

and hydrants, located along the edge of the flightline. The fuel pipeline

system was used to supply JP-4 jet fuel and AVGAS from the tank farm to the

hydrant system via the four 50,000 gallon USTs. Unused fuel was delivered

from the flightline back to the 50,000 gallon USTs via a 12,000 gallon UST

(see Appendix A). Both systems were installed around 1952 and remained in Iservice until the systems were abandoned in 1973 (F-102 aircraft phased

out); however, the four 50,000 gallon USTs at the Pump House have continued

to be in service (fuel is transported to and fra the USTs by truck and

pumping).

o The area used for fire training exercises by the ANGB is located on the

east side of International Avenue at Darwin Road. The site consists of a

rectangular open earth area, approximately 600 by 800 feet. There is no

lining or containment structure for the area. This location has been used Iby the ANGB since the early 1950s in conjunction with other agencies over

the years for various fire training exercises. The fire training area is

not located on current ANGB property. It is currently owned by Dane

County. Fire training exercises have been discontinued at the site since

August 1986. At that time, the director of the Dane County Municipal

Airport/Truax Field ordered a halt to all training exercises until an

assessment could be made as to the environmental consequences of continued

training exercises.

o There are five oil/water separators located on the Base. They are

associated with buildings and USTs as follows:

Building Name/No. UST (Tank I.D. No.)

AGE Shop/401 401-1Fire Station/403 403-2Engine Shop/409 409-2 mFuel Cell Maintenance Shop/414 414-4Motor Pool/1000 1000-3

IV-8

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All oil/water separators are presently active. The skmmings (oil and

grease) frm the separators flow directly to the associated USTs and the

effluent flows directly to the sanitary sewer system. There are no

reported incidences of major leaks or spills fran the oil/water separators

with the exception of occasional separator malfunctions that cause the

skimnings to escape to the sanitary sewer system. The associated USTs are

also listed in Appendix A.

o There are 33 USTs located on the Base. The USTs have been used to store

jet fuel, gasoline, fuel oil, waste oils, diesel fuel, and detergents. Two

of the USTs, one located at the AAFES Building and the other connected with

the fuel hydrant system, have been abandoned. The UST at the AAFES

Building has been out of service since 1953. Reportedly, this UST has

been empty since that time and there have been no associated leaks or

spills. The UST connected with the fuel hydrant system has been out of

service since 1952, when the entire fuel hydrant system was abandoned.

This UST has been empty since that time and there have been no associated

leaks or spills. The remaining 31 USTs are presently active with no

reported incidences of leaks or spills. Four of the active USTs are

associated with Site No. 1, JP-4 Fuel Spill No. 1 (see Section IV.B). Five

of the active USTs store waste oil from five oil/water separators (Tank

I.D. No. 401-1, 403-2, 409-2, 414-4, and 1000-3). The USTs that store

waste oils, waste solvents, etc., are periodically pumped (emptied) and

disposed of through the Defense Reutilization Marketing Office. A complete

list of USTs can be found in Appendix A.

IV-9

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IO-T

W T~ CREE El- I

PARII

I _7

IA

U LEGEND

_______ Direction

of Flow

SCALAC 1 =2415'

FIGURE IIIE. SURFACE DRAINAGE SYSTEI,128th TFW, WISCONSIN ANG, TRUAX FIELD, MADISON WISCONfSIA

(Source: USGS 7.5 Minute Topographic Maps; DeForest and EadiLon 1:st, 1983)II 111-9

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Ihas resulted in a reduction of the groundwater discharge to wetlands, 3lakes, and streams.

Truax Field ANGB receives all of its drinking water from the city of

Madison. Likewise, all wastewater from the ANGB is carried via

sanitary sewer lines to a city of Madison wastewater treatment plant.The nearest groundwater use is from five wells located outside the

boundaries of the ANGB about one and a half miles southwest. Four of ithese wells serve the Oscar Mayer plant and are currently active.

One of the wells has also served the Oscar Mayer plant and is 3currently inactive.

D. CRICAL HABNMS/EWIRD O THRFMMM S CU) S i

According to an environmental inpact statement prepared for the construction iof an Aircraft Engine I & R Shop and conversion of OA-37 to A-10 Beddownaircraft, there are no endangered or threatened species of flora or fauna in ithe vicinity of the ANGB. Cherokee Marsh, located adjacent to and north-

northwest of the ANGB, contains an undisturbed fen which includes cattail 3marsh, sedge meadow, and wet prairie vegetation as well as providing a suitable

habitat for the short-eared owl, red-tailed hawk, bobolinks, and cranes. No

edangered or threatened species inhabit the marsh. Cherokee Marsh is isolated

from potential contamination from Truax ANGB by Starkweather Creek which

carries all drainage to lake Monona.

IIIII

III-10

i

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IV. SMI EFAUMN

A. ACIVITY REVIEWM

A review of ANGB records and interviews with past and present ANGB employeesresulted in the identification of specific operations within each activity in

which most industrial chemicals are handled and hazardous wastes are generated.

Table IVA summarizes the major operations associated with each activity,

provides estimates of the quantities of waste currently being generated by

these operations, and describes the past and present disposal practices for the

wastes. If an operation is not listed in Table IVA, then that operation has

been determined on a best-estimate basis to produce negligible (less than

5 gallons per year) quantities of wastes requiring ultimate disposal. For

example, an activity may use small volumes of methyl ethyl ketone. Such

quantities ccmmonly evaporate during use, and therefore do not present adisposal problem. Conversely, if a particular volatile compound is listed,

then the quantity shown represents an estimate of the amount actually disposed

of according to the method shown. Table IVB contains building names, numbers,

and addresses.

B. DISP)SAL/SPUL SITE nITrJYIFICN, EVAMI CN, AND HAZARD ASSESSMENT

Interviews with 19 ANGB personnel and subsequent site inspections resulted inthe identification of three disposal/spill/storage sites. It was determined

that none of the identified sites posed a significant potential for

envirornmental contamination by hazardous materials/hazardous wastes.

Accordingly, none of the sites are recommended for further IRP evaluation, and

were not scored by HAM. Figure IVA illustrates the locations of the three

identified sites.

I

IV-

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ITable IME. Building Numbers/Street Aresses i

128th TEW, Wisconsin Air National Guard, Truax Field, Madison, Wisconsin I3JIMIlN IIIDIN Sn;M

N1EE NAME ADREI

305 AAFES 2709 Hoffman Street307 NDI LAB 2625 Hoffman Street i311 NOD CUB 2401 Hoffman Street400 MAIN HANGER 3114 Mitchell Street401 AGE SHOP 3142 Mitchell Street402 SEC. POLICE/(004 3110 Mitchell Street403 FIRE STATICN 3116 Mitchell Street404 BASE OPS 3124 Mitchell Street405 POL PUMP HOUSE 2510 Pearson Street I406 AVIONIC/WEAPON REL HANGER 3130 Mitchell Street407 GUARD HOUSE 3112 Mitchell Street408 GUARD HOUSE 3128 Mitchell Street i409 ENGINE SHOP 3134 Mitchell Street410 FLIHT SIMUIAT BUIMfING 3138 Mitchell Street411 SIr'A'ZE SHED 2506 Pearson Street412 AIRCRAFT SHELTER 3118 Mitchell Street414 !'JEL CEL MAINEANCE SHOP 2508 Pearson Street415 POL OPERATIONS 2502 Pearson Street416 GENERATOR FUP POL 2504 Pearson Street i417 LOX 2512 Pearson Street499 LIFT STATION 3112 Mitchell Street500 O&T 3201 Mitchell Street501 GAITHOUSE 3202 Mitchell Street510 BASE SUPPLY 2222 Hoffman Street511 PAINT & DOPE STORAGE 2224 Hoffman Street600 OFFICE BUILING 3417 Mitchell Street900 MISCELANEOUS S1CAGE 3501 Mitchell Street1000 MOTOR POOL 2221 Hoffman Street1201 BCE STORAGE 2420 Pearson Street1202 SAND STORAGE 2320 Pearson Street1204 BCE STORAGE 2422 Pearson Street1205 ENGINE TEST STORAGE 2424 Pearson Street1206 ENGINE TEST STAND 2426 Pearson Street1207 BCE STORAGE 2314 Pearson Street1209 BCE STORAGE 2308 Pearson Street1210 BASE CIVIL ENG. 2310 Pearson Street1211 BCE FUEL STORAGE 2312 Pearson Street1212 MUNITIONS STORAGE 2202 Pearson Street1213 MUNITIONS STORAGE SHED 2204 Pearson Street I4000 TACAN CTH CV, Windsor

IV-4

I

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IV-5

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I

Site No. I - JP-4 Fuel Spill No. I (unrated) IFour 50,000 gallon underground storage tanks (USrs) (No. 405-1, -2, -3, and -4)

are located next to Building 405, the Petroleum, Oil, and Lubricant (POL) Pump

House. These tanks are constructed of cathodically protected steel and have

been in active use since 1952, the date of their installation. The tanks

currently contain JP-4 (jet fuel) used to refuel the aircraft on base. No

wastes are associated with this facility (see Appendix A).

On March 6, 1981, approximately 2,000 gallons of JP-4 spilled onto the ground

when one of the 50,000 gallon USTs overflowed during a loading operation.

Reportedly, an existing drainage ditch (about 100 feet long) next to the spill

was damned off. The fire department foamed the fuel and also flushed the fuel

to direct it toward the ditch. The fuel soaked into the soil and was covered

with straw. (Refer to Sections III.B and III.C for soil permeability and

groundwater depth.) By April 9, 1981, as directed by the Madison area

Department of Natural Resources, the affected soil was removed to a depth of

about 6 feet in the ditch, or to the limit of odor detection on the ditch side 3slopes. The material was then spread at 6 to 10 inches depth on four concrete

pads (used for mobile homes) that were located on what is now the parking lot

west of Building 500. The contaminated soil was turned during the following

summer to enhance volatilization. The next summer, 1982, the area was

excavated to a depth of at least 3 feet for a parking lot. The concrete pads

and contaminated soil were removed along with the excavated material and hauled

off base, and the area was asphalted the same year. Because of the corrective

measures taken to control contamination, the potential for additional

contamination is minimal.

Site No. 2 - JP-4 Fuel Spill No. 2 (unrated)

On August 3, 1985, approximately 100 gallons of JP-4 spilled onto the ground

due to a broken pipe on a transfer cart while loading used JP-4 into a waste

oil storage tank (No. 1201-1, see Appendix A). All fuel was contained by

diking and blotted up with absorbent blotters. The terrain in the area was

IV-6

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flat and the area was not adjacent to a body of water. Three 55 gallon drums

of contaminated earth were removed within 2 days of the incident. Because of

the corrective measures taken to control contamination, the potential for

additional contamination is minimal.

Site No. 3 - PCB Spi1 (unrated)

Three pole-mounted transformers in an outdoor electrical training station were

located next to and east of Building 1201. In 1983, one of the units was

leaking dielectric fluid onto the ground approximately 4 feet below. The PCB

concentration in the leaking fluid was tested and determined to be 1800 ppm.

The ground area affected by the leak amounted to approximately 3 square feet.

Soil samples were taken in and around the spill area; the test results

indicated PCB levels from 0.3 to 31.6 ppm. A total of three 55 gallon drums

of PCB-contaminated soil were removed and the area was retested for PCB

contamination. The transformers were also removed to prevent further

contamination. After removal, tests indicated background levels at less than

0.1 ppm. Because of the corrective measures taken to control contamination,

the potential for additional contamination is minimal.

C. OTHER PERTIT FACTS

o The wash rack area, outside and adjacent to the Main Hangar (Building 400)

and Aircraft Shelter (Building 412), was used to wash aircraft until about

1983. From 1983 to the present time, washing has been conducted inside the

Aircraft Shelter and occasionally inside the Main Hangar.

o During the site visitation to the Motor Pool and AGE, an apparent waste oil

residue was observed on the ground around the filling ports of the

associated USTs (see Appendix A). Reportedly, the residue was the result

of minor spillage during filling and removing (pumping) of waste oils.

There are no additional reported spills or leaks associated with these

USTs.

o An abandoned fuel pipeline system and fueling/defueling hydrant system are

located at the ANGB (see Appendix A). The fuel pipeline extends from an

IV-7

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abandoned tank farm (outside of the ANGB) to four 50,000 gallon USTs, next

to the Petroleum, Oil, and lubrication (POL) Pump House. The hydrant

system line extends from the Pump House to a series of filter meter pits

and hydrants, located along the edge of the flightline. The fuel pipeline

system was used to supply JP-4 jet fuel and AVGAS from the tank farm to the

hydrant system via the four 50,000 gallon USTs. Unused fuel was delivered

from the flightline back to the 50,000 gallon USTs via a 12,000 gallon UST

(see Appendix A). Both systems were installed around 1952 and remained in Iservice until the systems were abandoned in 1973 (F-102 aircraft phased

out); however, the four 50,000 gallon USTs at the Pump House have continued

to be in service (fuel is transported to and from the USTs by truck and

pumping).

o The area used for fire training exercises by the ANGB is located on the

east side of International Avenue at Darwin Road. The site consists of a

rectangular open earth area, approximately 600 by 800 feet. There is no

lining or containment structure for the area. This location has been used iby the ANGB since the early 1950s in conjunction with other agencies over

the years for various fire training exercises. The fire training Eea is

not located on current ANGB property. It is currently owned by Dane

County. Fire training exercises have been discontinued at the site since

August 1986. At that time, the director of the Dane County Municipal

Airport/Tnax Field ordered a halt to all training exercises until an

assessment could be made as to the environmental consequences of continued

training exercises.

o There are five oil/water separators located on the Base. They are

associated with buildings and USTs as follows:

BuildinQ Name/No. UST (Tank I.D. No.)

AGE Shop/401 401-1Fire Station/403 403-2Engine Shop/409 409-2 IFuel Cell Maintenance Shop/414 414-4

Motor Pool/1000 1000-3

IV-8

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I All oil/water separators are presently active. The skinirgs (oil and

grease) frcn the separators flow directly to the associated USTs and the

effluent flows directly to the sanitary sewer system. There are no

reported incidences of major leaks or spills from the oil/water separators

with the exception of occasional separator malfunctions that cause the

skimmings to escape to the sanitary sewer system. The associated USTs are

also listed in Appendix A.

o There are 33 USTs located on the Base. The USTs have been used to store

jet fuel, gasoline, fuel oil, waste oils, diesel fuel, and detergents. Two

of the USTs, one located at the AAFES Building and the other connected with

the fuel hydrant system, have been abandoned. The UST at the AAFES

Building has been out of service since 1953. Reportedly, this UST has

been empty since that time and there have been no associated leaks or

spills. The UST connected with the fuel hydrant system has been out of

service since 1952, when the entire fuel hydrant system was abandoned.

This UST has been empty since that time and there have been no associated

leaks or spills. The remaining 31 USTs are presently active with no

reported incidences of leaks or spills. Four of the active USTs are

associated with Site No. 1, JP-4 Fuel Spill No. 1 (see Section IV.B). Fiv

of the active USTs store waste oil from five oil/water separators (Tank

I.D. No. 401-1, 403-2, 409-2, 414-4, and 1000-3). The USTs that store

waste oils, waste solvents, etc., are periodically pumped (emptied) and

disposed of through the Defense Reutilization Marketing Office. A complete

list of USTs can be found in Appendix A.

IV-9

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V. ONCLIS

As a result of information obtained through interviews with 19 current and

foner ANGB personnel, a review of ANGB records, and field observations, three

sites have been identified as potential disposal/spill/storage sites. The

three sites are as follows:

o Site No. 1 - JP-4 Fuel Spill No. 1 (unrated)

o Site No. 2 - JP-4 Fuel Spill No. 2 (unrated)

o Site No. 3 - PCB Spill (unrated)

The potential sites were eliminated from further study because they were not

contaminated with hazardous materials/hazardous wastes, and a potential for

migration did not exist. Therefore, they pose no significant hazards to public

health or the environment. Subsequently, the sites were not rated by HARM.

V-1

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VI. MOIENIDM'INS

Based upon the findings of this report, PEER Consultants, P.C., does not

consider any of the three identified sites at the ANGB as susceptible to

contaminant migration or presenting a risk to public health and the

environment. Therefore, implementation of further IRP evaluation is not

* reccamnded.

VI-I

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GWFSSAIRY OF TER

AQUIER - A geologic formation, grup of formations, or part of a formation

that contains sufficient saturated permeable material to yield economical

quantities of water to wells and springs.

CQrAMENTU - As defined by Section 101(f) (33) of Superfund Amendments and

Reauthorization Act of 1986 (SARA) shall include, but not be limited to any

element, substance, cmpound, or mixture, including disease-causii agents,

which after release into the environmit and upon exposure, ingestion,

inhalation, or assimilation into any organism, either directly from the

environment or indectly by ingestion through food chains, will or may

reasonably be anticipated to cause death, disease, behavioral abnormalities,

cancer, genetic mutation, physiological malfunctions (including malfunctions in

reproduction), or physical deformation in such organisms or their offspring;

except that the term "contaminant" shall not include petroleum, including crude

oil or any fraction thereof which is not otherwise specifically listed or

designated as a hazardous substance under:

1. any substance designated pursuant to Section 311(b) (2) (A) of the

Federal Water Pollution Control Act,

2. any element, ccupound, mixture, solution, or substance designated

pursuant to Section 102 of this Act,

3. any hazardous waste having the characteristics identified under or

listed pursuant to Section 3001 of the Solid Waste Disposal Act (but

not including any waste the regulation of which under the Solid Waste

Disposal Act has been suspended by Act of Congress),

4. any toxic pollutant listed under Section 307(a) of the Federal Water

Pollution Control Act,

5. any hazardous air pollutant listed under Section 112 of the Clean Air

Act, and

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II

6. any imminently hazardous cheical substance or mixture with respect

to which the administrator has taken action prsuant to Section 7 of

the Toxic Substance Control Act;

and shall not include natural gas, liquefied natural gas, or synthetic gas of

pipeline quality (or mixtures of natural gas and such synthetic gas).

CRITICAL HABITAT - The native enironment of an animal or plant which, due

either to the uniqueness of the organism or the sensitivity of the environment,

is susceptible to adverse reactions in response to environmental changes such

as may be induced by chemical cntaminants.

CL STF M - Pertaining to a gently sloping plain which terminates in a steep

slope on one side.

DIP - In geology, the angle at which a stratum or any planer feature is

inclined from the horizontal. IDOWNGRADIEMT - A direction that is hydraulically downslcpe, i.e., the direction

in which groundwater flws.

MIFT - Any rock material, such as boulders, till, gravel, sand, or clay,

transported by a glacier and deposited by or frcm the ice or by or in water

derived from the melting of the ice.

ENDNGEE SPECIES - Wildlife species that are designated as endangered by the

U.S. Fish and Wildlife Service. I

FEN - Itw, swampy land.

GRONIWkTER - refers to the subsurface water that occurs beneath the water

table in soils and geologic formations that are fully saturated.

IG1-2I

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HAR - Hazard Assesmnt Rating Methodology - A system adcpted and used by the

U. S. Air Force to develop and maintain a priority listing of potentially

I contaminated sites on installations and facilities for remedial action based on

potential hazard to public health, welfare, and environmental impacts.

(Referec: DEQPPM 81-5, 11 Dt er 1981).

HAS - Hazard Assessment Score - The score developed by using the Hazardous

Assessment Rating Methodology (HARK).

HAZARDOUS MATERIAL - Any substance or mixture of substances having properties

capable of producing adverse effects on the health and safety of the human

being. Specific regulatory definitions also found in OSHA and wr rules.

HAZARDOUS WASTE - A solid or liquid waste that, because of its quantity,concentration, or physical, chemical, or infectious characteristics may

1. cause, or significantly contribute to, an increase in mortality or an

increase in serious irreversible or incapacitating reversible

illness; or

2. pose a substantial present or potential hazard to human health or the

environment when improperly treated, stored, transported, disposed

of, or otherwise managed.

LACUSTRINE - Produced by or belonging to lakes.

HYERAULIC ==MUCYIVITf - The rate of flow of water in gallons per day through a

cross section of one square foot under a unit hydraulic gradient, at the

prevailing temperature (gpd/ft2 ). In the SI system, the units are m3/day/m 2 or

m m/day.

HYERAILIC GRADIE2l - 7he rate of change in total head per unit of distance offlow in a given direction.

G1-3

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mMIGRATION (ctaminant) - The movement of contaminants through pathways(grundwater, surface water, soil, and air).

MIAD4E - Drift, deposited chiefly by direct glacial action, and having m

constructional tcpography i -depent of control by the surface on which the

drift lies.

IpEABILITY - The capacity of a porous rock, sediment, or soil for m

transmitting a fluid without impairment of the structure of the radium; it is a

measure of the relative ease of fluid flow under unequal pressure.

POROSITy - The percentage of the bulk volume of a rock or soil that is occupied

by interstices, whether isolated or connected.

SURFACE MATM - All water exposed at the ground surface, including streams, mrivers, ponds, and lakes.

THREATEN4ED SPECIE - Wildlife species who are designated as '"Threatensed" by the

U.S. Fish and wildlife Service.

TOp)GRM - The general conformation of a land surface, inCltdix its relief

and the position of its natural and manmde features.

wmw TABLE - The upper surface of a zone of saturation.

WErLANDS - An area subject to permanent or prolonged inundation or saturationthat exhibits plant communities adapted to this envircment. IWI mESS AREA - An area unaffected by anthrcpogenic activities and deemed

worthy of special attention to maintain its natural condition- 3

Im

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1. "Air National Guard Installation Restoration Program," frum ANGB files.

2. "Environmawna Inpact Analysis, 128TASW, Truax Field, Madison, Wisconsin,"(EIA for proposed mission dhange and aircraft conversion), dated February11, 1981, from ANGB files.

3. Federal Register (47 FR 31224), 16 July 1982.

4. Federal Register (47 Fr 31235), 16 July 1982.

5. "Hazardous Materials/Waste Inventory; Truax Field, Wisconsin," from ANGBfiles.

6. Henschel, Johm P. Correspondence from National Electric, Inc., to BobCopas, WI ANG, dated October 31, 1983.

7. "Inventory of Hazardous Materials/Hazardous Wastes by Shops," from ANGBfiles.

8. Kaufman, R. J. 1970. Hydrogeology of Solid Waste Disposal Sites inMadison, Wisconsin. Ph.D. Thesis, University of Wisconsin, Madison.

9. "Madiscn ANG, 30th Anniversary," from ANGB files.

10. Osipoff, George, WI ER. Correspondence/memorandum to Perry Manor andHenry Kern dated April 9, 1981 (file ref. 3410).

11. Peters, Roger. 1988. Personal and written cummunication, Wisconsin StateGeological Survey, Madison, Wisconsin.

12. "Pollution Incident Report," and attachment, dated August 9, 1985, fromANGB files.

13. Post, Robert F., Department of the Army, St. Paul District Corps ofEngineers. Correspondence/emorandum CENCS-ED-M (200) to Cmumader, NorthCentral Division (Attention: CECD-ED-7M / Mr. Bob Warda).

14. "Southern District Summary Spills Report," Wisconsin ER, Madison,Wisconsin, date of incident March 6, 1981.

15. "Southern District Summary Spills Report," Wisconsin ER, Madison,Wisconsin, date of incident October 1, 1983.

16. "Southern District Summary Spills Report," Wisconsin ER, Madison,Wisconsin, date of incident August 31, 1985.

IBi-iI

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I

17. "Truax Air Force Base, Madison, Wiscorsin, Hydrant Refueling Facilities,Expansion of Existing Facilities, General Plot Plan," U.S. Army Corps ofEngineers, Mard 11, 1952, fran ANGB files.

18. "U. S. Army Corps of Engineers, St. Paul District, Envirvmental IRestoration Defense Acoamt, Findings and Determination of Departrent ofDefense Responsibility, Truax Field, BO5WI004800."

19. "Wisconsin Air National Guard, Madison, Silver Anniversary, 6 Octoer1948-5 October 1973,"1 fran AG files.

IIIIIIIIIII

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APPENDIX A

LIST OF UNDERGROUNDSTORAGE TANKS

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APPENDIX B

RESUMES OFSEARCH TEAM MEMBERS

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7BaMS S. %as

HUTI0N B.S. Civil Engineering, University of Wyoming, 1966B.A. History, Biology, University of Wyoming, 1964

aMIFIMTINRS Certified Safety Executive - 1987Certified Safety Manager - 1987Certified Safety Specialist (Industrial Hygiene) - 1987Certified Industrial Hygiene, Comprehensive Practice (NotCurrent) - 1975

PROFESSIONAL

1987-Present PEER CONSULTANTS, P. C.Oak Ridge, TNProject mnge

Senior Project Manager presently directing these tasks: theNew Boston AFS RI/FS and Robins AFB and Newark AFB SpillPrevention and Response Plans. Tedhnical review andengineering support to DOE on Tinker AFB storm drainagesystem evaluation and Dover AFB, cadmium reduction in theindustrial waste stream. Preliminary assessments for 13 AirNational Guard Bases.

1966 - 1987 U. S. AIR FORCE

Directed the activities of the Occupational & EnvironmentalHealth Laboratory in providing consultation, technicalguidance, and on-site assistance in industrial hygiene, airand water pollution, entomology, health physics, andbioenvironmental engineering at all Air Force bases in thePacific area including Hawaii, Japan, Korea, Guam, and thePhilippines. As director, developed the plans forestablishing an asbestos identification and countingcapability to support Air Force bases in the Pacific. Hadresponsibility for managing the administration and budgetingof operating funds for the organization, p L MWr= ofequipment and supplies, day-to-day supervision of laboratorypersonnel, and conducting selected field studies. Personneldirectly supervised included chemists, engineers, medicalentmologist, and specialized technicians in each functionalarea.

B-I

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Thomas S. WebbPage 2

As Chief, Bioenvironmental Engineer, Headquarters US AirForce, directed the Bioenvironmental iEngineering/Occupational Health programs for all Air NationalGuard facilities in the United States and its territories.Established policy and guidance by writing and revising AirNational Guard regulations and by supplementing Air Forcepublications. Was the only full time certified industrialhygienist in the cmmand and personally conducted IH surveysincluding asbestos identification and evaluation; alsoassisted in developing plans and specifications for managingor removing asbestos in Air National Guard facilities.Budgeted for and technically directed the Phase IIAInstallation Restoration Program at five ANG bases.Represented the National Guard Bureau (NGB) Surgeon on theAgency Environmental Protection Camttee and the NGBs onthe DoD Safety and Occupational Health Policy Council.Served on DoD subc= ttees and provided testimony toCongressional ocmittees in area of expertise.

Directed the Bioenvironmental Engineering/EnvironmentalHealth program for Clark AB, John Hay AB, and Wallace AS.Evaluated ccmuuty and work environments and recamndedcontrols to keep occupational and enviromental stresseswithin acceptable limits. Established and conducted theenvironmental monitoring program for Clark AB.

As the Command Bioenviromental Engineer, Headquarters AFReserve, developed occupational health cnd environmental.protection plans, policy, and programs for all AF reserve ibases. Also developed and taught a two week training coursefor all AF Reserve bioenvironmental engineering technicians.

As Chief, Bioenvirormental Engineering, Robins AFB, Georgia, Iconducted an industrial hygiene program for 18,000 civilianand 5,000 military workers. Performed industrial hygieneevaluations of aircraft operations, paint stripping,industrial radiography, microwave radiation, laser and otherindustrial facilities.

Has also served as Chief, Bioenvirormental Engineering, HillAFB, Utah; [Nang AB, Vietnam; and Wright-Patterson AFB,Ohio.

IB-

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T'homas S. WekbPage 3

As the bioenvironmiental engineer at the above bases,conducted numeous noise surveys for determining noise levelsto which base personnel were exposed. Is also thoroughlyfamiliar with land use planning with respect to aircraftnoise having conducted such evaluations for both Hill andRobins APB. These latter evaluations generated Idn oontcursfor then current aircraft operations, as well as projectedcontours for future aircraft conversions and modifications.

As the Bioenvirormetal Engineer at five Air Force basesover a period of twelve years, collected, prepared,and interpreted results from base water samples submitted for

-- bacteriological and chemical content analysis. As C mmanderof Operating Ication AD USAF Occupational and EnviromentalHealth Laboratory, directly supervised analytical personnelwho performed analysis of lead and other metals in water andwas directly responsible for appropriate analyticalprocedures and accuracy of data. In addition, provided

- consultative services concerning health and environmentaleffects to bases experiencing abnormally high levels ofmetals in drinking water. At Wright-Patterson AFB, assistedI in all environmental protection evaluations and conductedstack gas monitoring of all coal-fired heating plants onbase. At Hill AFB, was one of the principal authors of theAir Force's first Enviromental Inpact Statments (1970-71).

FUERZCATICNS:

"Exposure to Radio Frequency Radiation from an Aircraft Radar Unit," Aviation,

-Space, and Environmental Medicine, November 1980

"For a Breath of Clean Air", AF Aerospace Safety Maazine, March 1975

"Baseline Industrial Shop Surveys," AF Medical Service D iest, April 1973

"Knee Problems Observed in Weapons Loading Personnel," AF Medical ServiceDis, March 1970

"Lasers - A New Problem for Bioenvironantal Engineers," AF Medical Service, March 1969

"Use of Iodine as a Swimming Pool Disinfectant," AF Medical Service Dicet,July 1967

I

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I

ARBIMI R. WAGNER

ELUCATIC B.A. Geology, University of Colorado, 1977 n

1987-Present PEER CQSULMWIS, P.C.Oak Ridge, 7N IPrepares preliminary assessments for Air National Guard Basesunder the Installation Restoration Program (IRP), technicaland research assistance on U. S. Air Force hazardous wastesites programs, location and removal of underground storagetanks, and a Remedial Investigation Report/Plan for East ForkPoplar Creek at the Y-12 Plant in Oak Ridge, Tennessee.

1987 ARDAMAN AND ASSOCIATESSarasota, FL

~r~q Technician IResponsibilities included geologic investigations such assoil borings and analysis, auger and rotary rig drilling forsubsurface investigations, hydrogeologic investigations andfoundation studies.

1980-1987 DERAID EXPLRATION CNSULZANTS, INC.Austin, TXSenior Geologist

Project management including seismic and magnettelluric crewsupervision, seismic data processing supervision, datainterpretation, technical report writing, and projectprcposal and budget management for governmnt and privatesector projects. Traveled extensively throughout the U.S.and China.

1978-1980 KEWILL, INC.Maryville, TNGeolois

sibilities evolved around the Central Tennessee oil and

gas prospect evaluation from initial planning stages throughwall cmpletion, coal and mineral exploration and reserveestimation studies including surface and underqround geologic Imapping, and laboratory duties for quality control at alimestone mine.

B-4

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Anthony R. Wagner

Page 2

RMIGMI Licensed Professional Geologist, State of North Carolina -License Number 526

HR)FESIRALENational Water Well Association/Association of Ground Water

Scientists and Ezgineers

American Association of Petroleum Geologists

Society of Exploration Geophysicists

PUBUICTI@[S High Resolution Seismic Surveys and Their Applications toCoal Exploration and Mine Development: Case Histories, 1984,(abstract), AAFG Bull., V. 68, No. 7.

The Application of High Resolution Seismology to theDelineation of Faulting and Coal Seam Thickness: AContinuing Case History, 1984. In Proceedings of the 1984Rocky Mxmtain Coal Symposium, Bismarck, North [dkota.

B-5

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1EVIN MNE PCK1

IT rTIIn B.S. Civil Engineering, West Virginia University, 1981Currently enrolled in the graduate Environmental EngineeringProgram at the University of Tennessee, Koxville

c3m'I]IcA IQ Egi In-Training, 1987

PRFESIR4AL

1987-Present PEER CONSUTAI1NS, P.C.Oak Ridge, TN

Civil Enineer

Prepared a preliminary assessment for the Wisconsin AirNational Guard under the U. S. Air Force Installation IRestoration Program, which involved identifying past spill ordisposal sites posing a potential and/or actual hazard topublic health and environment. Provides techical assistanceon a RCRA Feasibility Investigation for East Fork PcplarCreek in Oak Ridge, Tennessee.

1984-1987 BARE VGE Xt4ER SUMN AND CANNONKnoxville, TNCivil Rxjixeer

Involved in planning, design, and construction phases ofwater lines, sanitary and storm sewers, and site develcpent.Aided in plannin, reviewed vendor drawings, and preparedoperation and maintenance manuals for wastewater treatmentfacilities.

1982-1984 TCPKS BEQM1, INC.Taft, IA

Responsibilities included resolving field installationproblems, reviewing construction plans and documentation, andinspecting structural steel for Waterford III Steam ElectricStation, Taft, Louisiana.

1982 IANIM afION COMPANYFulton, MO

Reqoibilities included inspecting pipe suport systems andmaintaining production schedules for Calloway Nuclear Power IPlant, Fulton, Missouri.

I

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Kevin Wayne PackPage 2

1974-1982 Technician, H. C. Nutting Geotechnical Engineers, Charleston,Sumers W; Enginering Aide, WV Dpartment of Natural Rescurces,

Ch2arleston, WV; Laborer, E. E. Moore Construction Clmoany,South Charleston, WV.

i

IiiIiiiB-I

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IIIIIIII APPENDIX C

i OUTSIDE AGENCYCONTACT LISTIIIIIIIIII

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UTSIDE AGENCY CCUWCT LIST

1. State laboratory of Hygiene465 Henry MattMadison, Wisconsin 53706

2. Wisconsin Geological Survey3817 Mineral Point RoadMadison, Wisconsin 53705

3. State of WisconsinDepartbnt of Natural Resatrces3911 Fish Hatchery RoadMadison, Wisconsin 53711

4. U. S. Geological Survey - Water Resources6417 Nornandly LaneMadison, Wisconsin 53706

5. City of Madison Engineering Division210 Martin Luther King, Jr., Blvd.Madison, Wisconsin 53710

6. Dane County Regional AirportTruax Field4000 International LaneMadison, Wisconsin 53704

7. Defense Reutilizatin and Marketing Office (MM)Building 2184Fort McoySparta, Wisconsin 54656

8. Departmnt of the ArmySt. Paul District, Corps of Engineers1135 U. S. Post Office & Custom HouseSt. Paul, Minnesota 55101-1479

C-I

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APPENDIX D

USAF HAZARD ASSESSMENTRATING METHODOLOGY

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USAF HAZ ASSESS T RATNG PM0f

The Department of Defense (DoD) has established a cmprehensive program to

identify, evaluate, and control problems associated with past disposal

practices at DoD facilities. One of the actions required under this program is

to:

develop and maintain a priority listing of contaminatedinstallations and facilities for remedial action based anpotential hazard to public health, welfare, and environmntalinpacts. (Reference: LEQPPM 81-5, 11 December 1981).

Accordingly, the U. S. Air Force (USAF) has sought to establish a system to set

priorities for taking further actions at sites based upon information gathered

during the Preliminary Assessment pbase of its Installation Restoration Program

(IRP).

RPOSE

The purpose of the site rating model is to provide a relative ranking of sitesof suspected contamination from hazardous substances. This model will assist

the Air National Guard in setting priorities for follow-on site investigations.

This rating system is used only after it has been determined that (1) potential

for contamination exists (hazardous wastes present in sufficient quantity), and

(2) potential for migration exists. A site can be deleted frcm considerationfor rating on either basis.

SPTION OF MDEL

Like the other hazardous waste site ranking models, the U.S. Air Force's site

rating model uses a scoring system to rank sites for priority attention.

However, in developing this model, the designers incorporated some special

features to meet specific DoD program needs.

The model uses data readily obtained during the Preliminary Assessment portion

(Phase I) of the IRP. Scoring judgment and cumpitations are easily made. In

D-1

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I

assessing the hazards at a given site, the model develops a score based on the Imost likely routes of contamination and the worst hazards at the site. Sites

are given low scores only if there are clearly no hazards. This approach

meshes well with the policy for evaluating and setting restrictions on excess

DoD properties.

Site scores are developed using the appropriate ranking factors according to

the method presented in the flowchart (Figure 1A of this report). The site

rating form and the rating factor guideline are provided at the end of this

appendix.

As with the previous model, this model considers four aspects of the hazard

posed by a specific site: (1) possible receptors of the contamination, (2) the

waste and its characteristics, (3) the potential pathways for contamination

migration, and (4) any efforts that were made to contain the wastes resulting

from a spill.

The receptors category rating is based on four rating factors: (1) the

potential for human exposure to the site, (2) the potential for human ingestion

of contaminants should underlying aquifers be polluted, (3) the current and

anticipated uses of the surrourding area, and (4) the potential for adverse

effects upon important biological resources and fragile natural settings. The

potential for human exposure is evaluated on the basis of the total population

within 1,000 feet of the site, and the distance between the site and the base

boundary. The potential for human ingestion of contaminants is based on the

distance between the site and the nearest well, the groundwater use of the

uppermost aquifer, and population served by the groundwater supply within 3

miles of the site. The uses of the surrounding area are determined by thezoning within a 1-mile radius. Determination of whether or not critical

envirorments exist within a 1-mile radius of the site predicts the potentialfor adverse effects from the site upon important biological resources and

fragile natural settings. Each rating factor is numerically evaluated (0-3)

and increased by a multiplier. The maximum possible score is also cmputed.

The factor score and maximum possible scores are totaled, and the receptors

D>-2

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subsoore ccaputed as follws: receptors subcore = (100 x factor score

subtotal/naxinm score subtotal).

The waste c-aracteristics category is scored in three steps. First, a point

rating is assigned based on an assessment of the waste quantity and the hazard

(worst case) associated with the site. The level of confidence in the

information is also factored into the assess ent. Next, the score is

multiplied by a waste persistence factor, which acts to reduce the score if the

waste is not very persistent. Finally, the score is further midified by the

physical state of the waste. Liquid wastes receive the maximm score, while

scores for sludges and solids are reduced.

The pathways category rating is based on evidence of contaminant migration or

an evaluation of the highest potential (worst case) for contaminant migration

along one of three pathways: surface-water migration, flooding, and

groundwater migration. If evidence of contaminant migration exists, the

category is given a subscore of 80 to 100 points. For indirect evidence, 80

points are assigned, and for direct evidence, 100 points are assigned. If no

evidence is found, the highest score among the three possible routes is used.

The three pathways are evaluated and the highest score among all four of the

potential scores is used.

The scores for each of the three categories are added together and normalized

to a maximum possible score of 100. Then the waste management practice

category is scored. Scores for sites with no contaminant are not reduced.

Scores for sites with limited contaiment can be reduced by 5 percent. If a

site is contained and well managed, its score can be reduced by 90 percent.

The final site score is calculated by applying the waste management practices

category factory to the sum of the scores for the other three categories.

D-3

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I

HAZARDOUS ASSESSMENT RATING FORM INAME OF SITE

LOCATION

DATE OF OPERATION OR OCCURRENCE

OWNER/OPERATOR ICO4MENTS/DESCRIPTION

SITE RATED BY

1. RECEPTORSFactor MaximumRating Factor Possible

Rating Factor (0-3) Nultiolier Score Score

A. Population within 1,000 ft. of site 4 I

B. Distance to nearest well 10

C. Land use/zoning within 1 miLe radius 3

D. Distance to installation boundary 6 1E. Critical environments within I mite radius of site 10

F. Water Quality of nearest surface water body 6 Ie_

G. Groundwater use of uppermost aquifer 9

H. Population served by surface water supply within3 miLes downstream of site 6

I. Population served by groundwater supply within3 miles of site 6 I

Subtotats

Receptors subscore (100 x factor score subtotat/maximnun score sutotal)____

11. WASTE CHARACTERISTICS

A. Select the factor score based on the estimsted quantity, the degree of hazard, and the confidence Level ofthe information.

1. Waste quantity (S = small, M = medium, L • large)

2. Confidence level (C = confirmed, S = suspected)

3. Hazard rating (H - high, N a medium, L z tow)

Factor Subscore A (from 20 to 100 based on factor score matrix)

I. Apply persistence factorFactor Subscore A x Persistence Factor Subscore B

x _

C. Apply physical state multiplier ISubscore B x Physical State Multiplier Waste Characteristics Subscore

D-4 I

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iii. PATHWAYSFactor

MaximumRating Factor Possible

Ratina Factor (0-3) Multipt ier Score Score

A. If there is evidence of migration of hazardous contaminants, assign maximum factor subscore of 100 pointsfor direct evidence or 80 points for indirect evidence. If direct evidence exists then proceed to C. Ifno evidence or indirect evidence exists, proceed to B.

Siibscore ___

B. Rate the migration potential for 3 potential pathways: Surface water migration, flooding, and groundwatermigration. Select the highest rating, and proceed to C.

1. Surface water migration

Distance to nearest surface water 8

Net precipitation 6

Surface erosion 8

Surface permeabi l ity 6

Rainfall intensity 8 _

Subtotats

Subscore (100 x factor score subtotal/maximum score subtotal)

2. Flooding I I 1 I

Subscore (100 x factor score/3)

3. Groundwater migration

Depth to groundwater 8

Net orecipitation 6

Soil permeabili ty 8

Subsurface flows 8

Direct access to groundwater 8

Subtotals

Subscore (100 x factor score subtotaL/maximun score subtotal)

C. Highest pathway subscore

Enter the highest subscore value from A, B-, 3-2 or B-3 above.Pathways Subecore

IV. WASTE MANAGEMENT PRACTICES

A. Average the three subscores for receptors, waste characteristics, and pathways.

ReceptorsWaste CharacteristicsPathways

Total divided by 3 2

Gross Total Score

B. Apply factor for waste containment from waste management practices

Gross Total Score x Waste Management Practices Factor = Final Score

I D-5

I

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