transcript of public hearing of the jefferson proving ground … · 2016-02-29 · which is an...
TRANSCRIPT
DATE:
PLACE:
TIME:
PRESENT:
JEFFERSON PROVING GROUND RESTORATION ADVISORY BOARD
January 7, 1997
Salvation Army Headquarters 331 East Main Street Madison, IN 47250
7:00 P.M.
Mr. Paul Cloud, Co-Chairperson Mr. Richard Hill, Co-Chairperson Audience Members Sharon Shields, Court Reporter
s.rts. ~ s{!/t~ SHARON SHIELDS, REPORTER
3650 N. Old SR 62 MADISON, INDIANA 47250
(812) 265-2994
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A public hearing of The Jefferson Proving
Ground Restoration Advisory Board meeting was held in The
Salvation Army Headquarters, 331 East Main Street,
Madison. IN at 7:00P.M. on January 7. 1997.
OPENING STATEMENTS BY MR. PAUL CLOUD:
Okay. Good evening. Let's get
started. I'd like to welcome everyone to the Jefferson
Prcv1ng Ground Restoration Advisory Board meeting. This
1s our first meeting in 1997. I don't have much in the
way of introductory remarks. I hope everyone had a n1ce
Christmas and a Happy New Year. Without further ado I
w1ll turn 1t over to Richard and let him w~lcome you and
we can get on with the agenda.
OPENING REMARKS BY MR. RICHARD HILL:
0kay thanks Paul. I wculd. like to
welcome everybody here ton1ght and I de want to
apolcg1=e. We had an overhead proJector but the l1ght
burned out so we won't be able to use that thls evening.
I think maybe the handouts will suffice though. And we
have several presentations ~hat we are going to have
tor.:.ight th1nk it be best if we JUSt go ahead and get
:.Jl th :na:.
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MR. PAUL CLOUD:
I'm up first. A couple of things I
would like to insure is that you did sign in on the
attendance sheet so tha~ we have your name and address on
our ma1ling l1st. And we can keep you advised as to
future meet1ngs and information as perta1ns to the
Jefferson Proving Ground clean up. What I would
~alk cf Richard'~ statement of trouble with the
l .. .lKe to
projecto~. is the leasing and the transfer of the various
parcels of properties in a cantonment area at Jefferson
Proving Ground. I hope that everyone picked up a copy of
the handout there. The first few items are basically
historical information from the units, the documents that
we have in fact initiated and have signed. The first one
- again they just go in chronological order, first to
text and so on, was the pump station for the pump station
here downtown. As soon as we had a- I believe it's a
legal description of the property with the rights of way
for the pipeline that formal transfer should be complete.
The actual FOST, find~ng of su1tab~l1ty to transfer,
which is an envi~onmental document has been signed and it
was signed in February of last year. And the other paper
work 1s at the Corps of Engineers real estate office in
~ouisv~ile. The nex~ 1tern is the finding of su1tabi!ity
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Not only has that FOST been signed out the actual
transfer of the deed has been accomplished. It was
finalized on the 18th of November. Ms. Cathy Hale is now
the proud owner as she represents the Madison Port
AuthorltY of o~ilding 2l6 and the ra1lroad trackage on
the Proving Ground. The next item we have is the FOSL,
finding the suitability to lease for the cantonment area.
This was thirty-four (34) - approximately thirty-four
hundred (3400) acres in the cantonment area that went
through the property screening process and also went
through the invitation to b1d process. Mr. Ford of Ford
Lumber and Bu1lding Supply Company. was the successful
bidder on that in December of 1995. His high bid of five
point one ($5.1) million dollars was the h1gh bid on
that. We dld s1gn a FOSL with the follow on lease of
furtheran~e of conveyance. Last year the F0SL was Slgned
May lst. The lease was signed about two (2) weeks later.
Mr. Ford lS currently in th~ process of slowly sublett~ng
out some of the bulldings to some of the businesses here
1n town and we are star~1ng co see some econom1c ce-use
of the various fac1lities at the ?rov1ng Ground now. The
next document we had was later on last year just before
Thanksgiving and I'm sure you saw a number of articles in
the paper about the park parcel. That document was
Slgned c& the 5th of November and :~ currently is at the
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Corps of Engineers real estate office in Louisville also.
The next step in there will be to have a deed or transfer
document prepared. The Corps of Engineers is going to
meet with the County Commissioners to work out the
details on some of the specifics in that document. And
then they will be signing the deed sometime later this
year. It's not clear yet exactly what date we have for
that. The last one (1) is approximately a forty (40)
acre parcel that is for lack of a better description
bounded by Paper Mill and Woodfield Road in the Proving
Ground in the cantonment area. Mr. Ford has asked us to
transfer that to him. It contains six (6) buildings and
about forty (40) acres. And so we are in the process of
getting that document ready to be put out for review.
It's expected right now that either January or sometime
early February we will get that out for a thirty (30) day
review. That will come to all the RAB members. We will
have some copies at the Proving Ground if anyone would
like to come in and get a copy of it and take a look at
it and provide us any feedback on that. After that
thirty (30) day review we will look at resolutlon and
incorporation of any comments, put it back out for about
two (2) weeks for identification of what we call
outstanding issues, issues that cannot be incorporated
into the document for whatever reason. And that would be
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attached to the document and it would go up and be
reviewed by the person that has the authority to sign it.
In this case this document would be signed by
headquarters that is above my headquarters which would be
the Army Material Company in Alexandria. Right now we
expect that that document will probably be signed
7 sometime mid March. And then it would go to real estate
8 division in the Corps at Louisville again and they would
9 prepare the transfer documents to Mr. Ford. That is our
10 current schedule on that. Mike?
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MR. MIKE EARLY
Paul that is a FOST?
MR. PAUI. CLOUD:
That is a FOST yes. That's for
transfer of that approximate forty (40) acres bounded on
the two (2) sides by Woodfield and Paper Mill Road.
MS. I.AURA HODGES:
Does he have a specific purpose for
that area?
MR. PAUL CLOUD:
I'm told he does but I don't know all
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the details of it yet. Yes sir?
MR. JOHN HOLMES:
Where do these parcels lie in terms
of their relationship to the whole site?
MR. PAUL CLOUD:
The pump station is down - downtown
Madison basically on the river. The building 216 is in
the cantonment area. It's just south of the firing line.
It's in Jefferson--
MR. JOHN HOLMES:
Is it south of the main gate?
MR. PAUL CLOUD:
No it's north of the main gate. But
it's in the cantonment area. It's in Jefferson County.
The cantonment area is all in Jefferson County and it's
south- it's basically everything south of the firing
line. Krueger Lake area which was basically just as you
come in the main gate there was on the left of Woodage
Drive, approximately two hundred and thirty (230) acres
in a rectangular area there. That's in the cantonment
area. And then the Paper Mill and Woodfield Road par~el
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is if you are familiar with the cantonment area at all -
it's just slightly northeast of where our Site Management
Team is currently located, building 125, which is the old
fire station. Cathy?
MS. CATHY HALE:
The pump station. Could you talk a
little bit more about where that stands? Because the
last time I thought that a little more along.
HR. PAUL CLOUD:
We - we thought it was too. There
was an easement granted to the Army back when that pump
station was originally built back many, many years ago.
MS. CATHY HALE:
Right.
HR. PAUL CLOUD:
By the - I think it was the state but
it had some unique language in it. It said to the Army
only.
MS. CATHY HALE:
Has that been resolved now?
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MR. PAUL CLOUD:
I'm not sure that it has although I
understand that it should be shortly. As soon as it is
then paper work for the actual transfer should - what it
has to do is that when that issue is resolved then the
deed would go through the Army to have the Army sign it.
It would go through the City sponsor which in this case
is Health and Human Services and they would pass the
title to the City. The City similarly to Madison Port
Authority would then be the title nolder. Yes sir?
MR. DON BARNES:
In regards to that easement to the
State Hospital I have - I have provided a letter to the
Corps of Engineers from the State permitting the State in
allowing us an easement through their property when a
route is decided on.
MR. PAUL CLOUD:
Okay.
MR. DON BARNES:
At this point we don't know where the
easement should be because of the Veteran's
Administrat1on cemetery that's being put in there. So
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we're going to have to take on a different route. So I
would think that that letter should be sufficient.
MR. PAUL CLOUD:
We will check with the Corps and see
where it stands.
MR. DON BARNES:
Mr. Williamson has a copy of that
letter.
MR. PAUL CLOUD:
Mr. Williamson was back here today
talking with us and we will follow up with him. Mike?
MR. MIKE EARLY:
Will you ask him where we're at in
that?
MR. PAUL CLOUD:
We will check into that and we will
be able to get back with Ken and be able to provide him
with actually where that stands. Any other questions on
where the various leases and transfers with the various
sections of the cantonment area stand? Okay. I would
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like to now introduce Ms. Karen Mason-Smith from Region
5 of the EPA in Chicago who will introduce the next two
(2) speakers. Thank you. Karen?
MS. KAREN MASON-SMITH:
Good evening. I'm Karen Mason-Smith
and I'm with the United States Environmental Protection
Agency Region 5 office which is located in Chicago,
Illinois. And I would like to introduce the next two (2)
speakers. One (1) of the speakers is Dr. Mark Johnson.
And Mark is currently a toxicologist in our Superfund
office and he's been with EPA for approximately two and a
half (2 l/2) years. And the next speaker is Ms. Brenda
Jones. And Brenda has been an ecologist ecological risk
assessor for in our Superfund office also. And she's
been with EPA for approximately two (2) years. And
Brenda has about ten (10) years experience with a
consulting firm and Mark has done post doctoral research
at Columbia University. So I would like to present Dr.
Mark Johnson and after him would be Ms. Brenda Jones.
MR. MARK JOHNSON:
Thank you Karen. As Paul mentioned
we don't have an overhead projector so I'm going to have
to try to reconstruct some of these for you. In the
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handout materials I did have an outline though of the
presentation. And so we will try to go through that.
There's also following that a fact sheet that EPA put
together about the methods that we use within EPA to
assess environmental risk. You might find that of value
to you at some point after the meeting today to read
through. The last part of the handout is a glossary of
terms we use in the risk assessment field. And you might
also find this of use value if you're reading any
documents related to JPG, particularly the risk
assessment portion, and you're uncertain about a term you
might want to use it to look that up and to understand
some of the terms that are used. I will try to make sure
that my presentation will minimize some of the technical
terms but I will use some terms that I will try to define
for you. If at any point anything that I've said is
unclear please raise your hand and I will try to verify
that okay? If there's any questions don't hesitate to
interrupt me and I will try to answer those questions as
they tend to come up. Okay. The first portion is to
define what is risk. We can define risk in the very
simple terms of the likelihood of injury, disease or
death. The definition of environment risk is that
injury, death or disease ~hat's related to environmental
contamination. Sc for example in the case of JPG where
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it's undergoing a series of environmental investigations,
we're using the information we obtained from the sampling
of both the soil and ground water as a means of
predicting what might be the risk of that exposure to
those contaminated soil and water sources that result
from exposure. And so what we do in risk assessment then
is to attempt to predict what might be that risk. We are
not actually measuring the effects that maybe have
occurred in the past, but rather try to predict with the
information we have available what might be the risk of
any future exposure. Now in the second part I've - I've
itemized the proposed risk assessment process. And there
are four (4) steps that were defined by the actual
Academy of Sciences a number of years ago. And EPA has
adopted them as the peridine that we use for assessing
environmental risk. And the four (4) components listed
there are hazard identification, toxicity assessment,
exposure assessment and risk characterization. We will
go through each one of those in detail so you may
understand some of the basic steps in that assessment
process. So hazard identification is the first step. So
we have this information about contamination that's found
in the field. We assess what is the - the hazard that
may result from that exposure. And the source of
information that we try to extract from that we obtained
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from a number of areas of investigation. EPA maintains a
series of data bases on toxicity information about
specific chemicals. And one (1) of them is called Iris.
I-R-I-S, which stands for integrated risk information
system. This is a public access data base that we
maintain. It contains information about the toxicity of
over six hundred (600) chemicals that we commonly find in
environmental investigations. And we use that as a
resource then to evaluate what are the hazards that would
result from public exposure? We also have another -
other data bases. Another one is called Hiast, H-I-A-S
T, which is one (1) that's used in Superfund. It's
called Health Index Assessment Summary Tables and that
also is again a data base that is a bit more expansive
than Iris. And information in those data bases is
derived from a number of sources. One (1) is the result
of investigation about human exposure that are usually
the result of investigation of occupational exposures.
For example a couple like Benzene that is commonly found
is an industrial solvent is easy to precursor in the
synthesis of many organic compounds used in a variety of
manufacturing processes. It's also a component of
gas. The information we have of the hazards of Benzene
as a result of occupational studies of industrial workers
have identified the association of leukemia with Benzene
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exposure. Other examples might be - for example
vinyl chloride which is use as a precursor for the
production of poly plastics, PVC pipe. The examples were
evidence of the hazards of.vinyl chloride with the result
of the studies of workers and PVC in the -- industry
showing that the association of certain type of liver
cancer with vinyl chloride exposure. Things like arsenic
or mercury that results in studies of people being
exposed to contaminated food stuffs with arsenic and
mercury. So we use that information as a means of
evaluating what the hazards might be. We also have some
information about some animal studies that we use that
allow us to look at more quantitative aspects of hazard.
For example when we do an animal study we can control the
dose that we give an animal. We have some sense of what
the toxicity level might be. So we can distinguish a
safe level from a toxic level. So a lot of or a portion
of our data bases, Irish and Hiast, contain information
about animal studies. There is also other information
that we use that add more confidence that we have in this
information. There's also studies on how the body deals
with chemicals that we use in work or phonokinetics.
Those examples are where we have information about how
dividing a cow has certain chemicals. That gives us
important information about predicting the toxicity. So
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that's sort of a summary then of the components of the
hazard section. The next section is the toxicity
assessment where we can answer a question how toxic are
the components? How much do we need of a certain
chemical to induce a toxic effect? And here we are
relying on information and we generate what is called a
dose response curve. So dose certainly means the
concentration, the amount of chemical that you would take
in your body. And we're looking at the response.
Response could be death. Response could be liver damage
or kidney failure or some kind of chronic effect of
exposure. We try to find out what's in the relationship
of the dose as we present the dose with the effect. And
oenerally we've seen this type of relationship sort of
curve. Would there be a plateau? Would there be a
maximum response for a very high dose? We would also
have a point where there would be no effect. And a
number of points in between. And for each chemical that
we evaluate we try to construct a dose response curve so
we distinguish what's a safe level from that particular
amount. So we would call this point then the no effect
level. But in many cases we rely on animal data to make
this dose response curve. There's a lot of uncertainty
about trying to predict the results of dose response
curves in animals to actual human exposure. Animals tend
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to be very genetically similar whereas human populations
are quite varied. There are a lot of differences between
people's sensitivity to chemicals either related to age.
Elderly and children are much more sensitive to effects
of chemicals. There may be genetic difference between -
amongst us which affects the toxicity of chemicals in our
bodies. So we do that to - to bumper ourselves. To make
sure that we're making sure that we can make - make an
accurate assessment of what is safe in humans and provide
safety factors. And we call those uncertainty factors.
Why we did that was to modify this safe no effect level
and we come up with a term called a reference dose.
That's simply defined as the no effect level in humans.
And we derive that again by taking the no effect level we
find in the animal study on safety factors and come up
with safe dose in humans. And so for each chemical in
these data bases we have a reference dose that we
consider to be safe. Can be an exposure to that dose.
Any questions about that concept? Okay. Now there's
another - what I have described for you here is - applies
to chemicals that cause chronic effects or chronic
diseases but not related to cancer. We evaluate cancer
in a very different way. The reason for that is for
chemicals that cause cancer we do not assume any no
effect level. We assume that there is a lower cancer
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risk associated with dropping the dose, but there is not
a level which there is no effect. So in that case our
dose response curve never actually reaches a no effect
level. It is rather a straight line. So for chemicals
that cause cancer we use the term called slope line and
the document that I've handed out to you will describe in
a bit more detail about the - about that concept. The
points raised here is that cancer - there's not
considered a safe level but rather a slope process used
in assessing the risks. Okay. The third component is
the exposure assessment where we try to evaluate who is
being affected, who is being exposed, and by how much.
And there are a number of criteria that we use in
assessing the exposure in individuals that might be
exposed at a site like JPG. We would first look at the
critical criteria that we use. First of all is that
there has to be a source of the contamination either in
the ground or a contaminated chemical that has leaked out
and contaminated the soil or ground water. There has to
be a source of the chemical. The second component in
this area has to be in a media. It has to be in the
soil, the air, water, food stuffs that may result in
contaminated soil. So it has to be a means of spreading
the contamination in a way that we would be exposed to
that. The difference on it is that there has to be a
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point of contact. We have to have some way of coming in
2 contact with the contamination for there to be a risk.
3 Either by touching contaminated soil, by ingesting it or
4 by breathing contaminated air. The call is that there
5 has to be a route, some way, but there has to be a
6 routing, a way for the chemical to get into our bodies.
7 And if any of these components are not present at the
8 site then there really is no risk. There has to be what
9 is called a complete pathway. All these have to be
10 complete in order for us to do this assessment risk. So
11 for example if ground water were to be contaminated, but
12 the ground water is never in use for drinking water, is
13 never brought to the surface, there really is no purpose
14 of evaluating the risk because there's no exposure. So
15 this is the four criteria that we have to fulfill in
16 order for us to view it in a risk assessment. Once we've
17 completed that then we look at the - who is being
18 exposed. And we have a number of different scenarios one
19 might consider. One (1) might be a resident, someone who
20 will be living in the area who will be there virtually
21 the entire year and may be there many, many years. The
22 things we would look at would be the things like the
23 exposure rate how much air we breathe per day, how much
24 soil that we come in contact with in our everyday
25 activities, how much water we drink per day. Those are
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great determinations that we use. And we have some -
some statistical studies that give us some information
about the average amount of soil that people come in
contact with during the day, objectivity. Now for
someone who might be involved in industrial activity
work, maybe a maintenance worker, maybe a construction
worker, they might have more intensive kind of contact
with soil. We also have values that we use for
determining exposure rates. Those have to be included.
The second parameter we use is exposure frequency. How
frequently is someone exposed? If someone is living on
the property then we would assume that their exposure
would be for the entire year. So if there is a worker he
might be exposed on an average of two hundred and fifty
(250) days per year or so. If someone was there just for
recreational you would have a different value for
determining that. We want to make sure that we're -
we're appropriately characterizing the frequency of that
exposure for the activity. The third component that is
exposure duration. How long is someone exposed? Is it
thirty (30) years? Is it two (2) years? What is the -
the duration of that exposure? And that is an important
part of our charts. And the final one is the
concentration of the contaminant. Is it something that's
widespread? Is it very localized? What is the average
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concentration of that contamination that someone ought to
be exposed to either in water or in soil? So we factor
all these together to get an exposure estimate for each
each individual that might.be exposed. The final step
then is - would be risk characterization where we try to
integrate all that information, the hazard in with the
identification information and the toxicity of the
chemical. We estimate the exposure of individuals and we
try to calculate then what is the risk of that exposure?
And we come up with two (2) estimates. One (1) is called
a hazard index which simply is a ratio then of the
exposure that you have relative to the toxicity of the
chemical. If that is greater than one point o (1.0) we
see that as unacceptable. If it's less than one (1) we
consider that to be acceptable risk. That simply then
indicates that if it's above one (1) it means that it's
greater than we would expect to be a safe level. Below
that we would consider it to be safe. And the handout
does include a bit more information about the details of
how the hazard index is calculated.
MR. PAUL CLOUD:
Mark maybe you could explain what
would happen to the number if this particular chemical
came up greater than one (1) exposure? What would be the
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next step then?
MR. HARK JOHNSON:
Okay. The implications of an
assessment which came up with an estimate greater than
one (l) might be a requirement for the- for a clean up.
That includes soil that would need to be removed and
treated. If it was water that may mean that it would
have to be removed from the - no longer be used for
drinking water purposes. Whether it would also institute
perhaps a clean up of the ground water. If it was air
they would require that a containment for that exposure
so that it would no longer be released in the air and not
be available for breathing. So we consider this a
regulatory criteria that we use in screening data in a
risk assessment. And I mentioned that for cancer causing
chemicals we use different criteria. Now for cancer
risks I mentioned that we assume that there is no safe
level of exposure to a cancer causing chemical. But
rather what we have determined as a policy with the EPA
is that a value of one (1) in ten thousand (10,000)
exposed individuals - excuse me. An acceptable risk for
cancer is considered to be no greater than one (1) case
in ten thousand (10,000) exposed individuals. And that's
excess hazard cases. Now for the average population in
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the United States one (1) out of three (3) people will
get cancer. So we set a fairly conservative estimate of
1:10,000 cannot be related to this site exposure. We are
being quite conservative in doing that. Okay? You may
also see that term as =10-4. We also have a term that
1:1,000,000 or =10-6 to because that would be a very safe
level. If the risk is that or below we consider that not
to be an issue. It's only above this level (indicating)
that we are concerned about it. If it's between these
two (2) ranges then we consider that to be a management
decision that the BCT would make on whether or not they
were willing to accept that risk. So those are the main
components. What we do in addition to the calculation
for the risk that I've shown you here, we also describe
some of the details of the methods that we use, some of
the assumptions that we use, the assessments, some of the
uncertainties that we have, which there are many. Making
these estimates of risk involve a lot of assumptions and
uncertainties that we disclose in the risk assessment
document. And those are all debatable and things that
are - can be challenged. But we need to disclose what
goes on in the process. Yes please.
AUDIENCE MEMBER:
How many chemicals have you actually
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established as cancer risks before? You spoke of six
hundred (600) chemicals?
MR. MARK JOHNSON:
Right.
AUDIENCE MEMBER:
We probably create more than six
hundred (600) new chemicals every day that we go forward.
MR. MARK JOHNSON:
You're absolutely ri9ht. And that is
- those brings up an important point. There are probably
in existence maybe over ten million (10,000,000)
chemicals that are - have been used in production, have
been used in synthetic processes. The information that
we have about the toxicity of those is very low in terms
of the percentage of chemicals that we are now
potentially exposed to. Most of those that I've
mentioned in the data bases about a hundred (100) or so
we have values for cancer slope factor. There are many
chemicals that you can be exposed to them but don't have
any way of quantifying the risk. And there is another
uncertainty.
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AUDIENCE MEMBER:
You have your two (2) curves there.
MR. HARK JOHNSON:
Right.
AUDIENCE MEMBER:
The straight line curves. How - how
do they for instance we have an epidemic of asthmatic
individuals in this country probably due to a multitude
of things. But how do you fit a sensitizing material
that would cause something resembling an asthmatic in for
instance the iso-sinades? How do you put that in those
curves?
MR. MARK JOHNSON:
The issue to sensitization may be the
results of multiple chemicals exposure.
AUDIENCE MEMBER:
Or individual - individual chemicals.
MR. MARX JOHNSON:
Okay but there are two (2) aspects of
that. The individual sensitivity is something we
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certainly would acknowledge. That's another reason that
we justify the uncertainty, that bumper I mentioned.
That may be people who are particularly sensitive to
certain chemicals for a number of reasons that we need to
include and make sure that we're protecting the more
sensitive individuals. The second part of that, as
sensitization relates, people that miy be exposed to
certain chemicals and sensitizes them to other chemicals.
And that exposure to mixtures is more than you would
predict based on individual exposures. And that is a
severe uncertainty. And I acknowledge the fact that a
doubt in the evaluation of risk. We assume that their
attitude, their participation - maybe they're greater
than that. And that is something that we are more - we
are concerned about and EPA is beginning to fund some
studies to look at the effects of multiple chemical
exposures so we can try and get a handle on it, for an
example gasoline products. You know there are a whole
host of chemicals present in those petroleum products.
So if we assess the risk of each component individually,
we may under estimate the risk of exposure to the entire
mixture. So that's an example for where that may lead up
to. Does that answer your question?
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AUDIENCE MEMBER:
You can't answer it. It's not
answerable I'm sure.
MR. MARK JOHNSON:
The other point about iso-sinades.
There are end points that we have not evaluated. Usually
we have a - we try to predict the most sensitive effect
we can identify. But if we don't have quantitative
information about that fact, for example an induction of
asthma, we can't really incorporate that into the
assessment. We all - we are now usin9 the phrase we have
quantitative toxicity information. Any questions about
that? If I had had the projector overhead I would have
gone through a site - or a case study where we applied
information about a site and gone through that to give
you some information about the formulas we used. But I
don't want to confuse you further by trying to reproduce
those on the board. But we do have the handouts we
mentioned. If there's any questions you have on any
point in the future, my phone number and address are on
the handout. Please contact me. The final point I want
to make was the implications of the risk assessment for
making decisions. And I want to make the point that the
risk assessment we do is only one (1) component to making
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decisions. That - the results of the risk assessment has
to be placed into contact with other criteria. For
example the cost of - or economic consideration. There
may be community concerns that affect a final clean up
decision. There are also a host of other factors that
play into that and risk of the- risk is only one (l) of
those components. And we try to be - we consider the
risk assessment process to be a scientific process. We
try to make it as strict as possible with scientific
methods. And that we constantly up date the information
we have available. Okay. Any questions about what I've
covered so far?
HR. JOHN HOLMES:
In relation to this site, what
processes have you gone through in terms of the
assessment, this specific site?
MR. MARK JOHNSON:
Right. It's gone through and Paul
and Karen can speak to this in more detail. But what I
reviewed on the site was a remedial investigation or RI
phase which is certainly the first step in assessing the
site. And we've gone through rounds - two (2) rounds of
sampling information abo~t the number of sites and that's
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been with the inclusions about risk for each of those
sites. But I will refer you to the BCT though in terms
of the conclusions of those for each of the JPG sites. I
just wanted to give you a feel for the basic methods that
we use in assessing this.
MR. JOHN HOLMES:
Taking that a step further I think
you made a comment but you didn't answer my desires here.
The second part is have you found any contamination as a
result of these studies?
MR. MARK JOHNSON:
Well we have found contamination.
There's no question about that. In some cases it's what
we consider to be in acceptable range. In other cases we
find that it falls in a range to where we need to make a
decision. Is there a clean up required? In some cases
that is justified. And in other cases there may be other
options besides the clean up.
MR. JOHN HOLMES:
How do we get a reading on these as
it relates to portions of this project?
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MR. MARK JOHNSON:
That information I think maybe Paul
could touch on.
MR. PAUL CLOUD:
Let me try and answer that to the
7 best of my ability. The cantonment area which is the
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portion of the Proving Ground that has been made
available for economic redevelopment, the Army's
commitment to the environmental clean up of that portion
of the facility was to a life time re-use similar to when
the Army used the base as an active facility. In other
words we're looking at light, medium industrial with some
agriculture and possibly some residential. We are not
looking for unrestricted re-use clean up criteria where
we could have a complete residential development from
fence line to fence line. ~nd that not only includes the
environmental contaminants like the heavy metals or the
solvents that Dr. Jones (Johnson) was talking about but
that also applies in a similar context to the UXO i~ the
cantonment area. The Army made a commitment several
years aqo from the Secretariat's office that there would
be a clean up of the UXO and cantonment area down to the
four (4) foot below surface level. And we are in
the process of doing that now. Does that answer your
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question'?
.MR. JOBH HOLMES:
Not directly but we will let it lie.
MR. PAUL CLOUD:
Well if you have any further
questions I would be glad to discuss them with you.
Again that decision was made sometime ago and part of it
is due to economics. There is only so much money
available. If we cleaned up JPG to unrestricted re-use
- and Congressman Hamilton has been here and talked about
this also - if he were to introduce legislation that were
to provide money for JPG, either the cantonment area or
the whole facility for unrestricted re-use for all
contaminants down to bedrock basically which in some
places could be twenty (20) or thirty (30) feet - the
natural reaction would be for every other facility in
every other state well me too. And it just physically
isn't enough money for that.
MR. JOHN HOLMES:
Let me phrase my question a little
bit differently. If you were presented with a map of
certain portions of this site could you tell us whether
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it was acceptable or not acceptable?
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4 That depends on what portion of the
5 facility you are talking about. South of the firing line
6 the facility - the Army has entered into a lease
7 furtherance conveyance to the successful high bidder in
8 this case Mr. Ford. North of the firing line due to the
9 extensive UXO contamination and the depleted uranium two
10 thousand (2,000) acre parcel in the center, the Army
11 currently is retaining that property because currently
12 it's against the law, federal law, to transfer property
13 with UXO contamination on it.
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16 That's two thousand (2,000) acres in
17 the center?
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20 Two thousand (2,000) acres
21 essentially in the center of the Proving Ground has
22 depleted uranium, yes sir, that was used for depleted
23 uranium testing the last few years the Proving Ground was
24 open. And right now the Nuclear Regulatory Commission is
25 in the process of issuing - generating and then issuing
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environmenta1 impact statement on the Army's request for
what we call a restricted re-use termination of the
permit that the Army currently holds with the Nuclear
Regulatory Commission on that two thousand (2,000) acres.
If you need any more information on this I would be - I
would be more than glad to talk to you about it.
MR. JOHN HOLMES:
Okay.
MR. PAUL CLOUD:
Okay thank you.
MR. MARK JOHNSON:
Any other questions? Thank you.
Brenda?
MS. BRENDA JONES:
Hi you all. As Karen said earlier my
name is Brenda Jones. I wanted to clear up something on
the agenda just for Mark's sake. Mark and I are not
related. On the agenda Mark - Mark's last name is
Johnson, not Jones. So make sure that we clarify that on
the agenda. Mark and I are not related. As Karen said
my name is Brenda Jones. And first of all I would like
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to thank Karen for that introduction. I would like to
thank the RAB for inviting me here this evening. I would
like to thank you all for staying and stopping by and
listening to this. Tonight - it's going to be a little
bit difficult without having an overheard projector but
can everyone hear me?
AUDIENCE MEMBER:
Yes.
MS. BRENDA JONES:
Everyone can hear me fine?
AUDIENCE:
Yes.
MS. BRENDA JONES:
Great. One ( l) thing I'm a 1 it tl e
bit luckier than Mark tonight in that I made copies of
all my overheads so you all should have copies, two (2)
handouts that we use. One (1) handout has a box in it
that says ecology and ecological effects. If you have
that handout that is for your information. You can take
that with you and read at your leisure. You don't have
to read it tonight. That's just an extra handout with
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some information on basic ecology. Information on things
like what is a species? How do you define population?
How do you define communities? That's just kind of a
background information on ecology in case anyone didn't
doesn't remember their lOth grade Biology. The other
handout where it starts out with a box and says
ecological assessment. Does everyone have a copy of
that? It would help if you had a copy of that in front
of you because those are copies of my overheads. So I
can talk directly off of those if you have that right in
front of you. Okay Carol is going to pass a few out.
And like Mark I want - would like to say that if you have
any questions don't hesitate to interrupt me. I think
it's easier to answer questions or to ask questions as
you think about them rather than wait to the end. So do
not hesitate to raise your hand if you have any
questions. But within -within the Environmental
Protection Agency we are tasked I suppose to protect both
human health and the environment. What Mark has talked
to you about was the basis of a human health risk
assessment but I'm going to talk to you a little bit
about what is the basis of ecological risk assessment.
The first page of my handout defines what an ecological
risk assessment is. And that is it can be qualitative or
quantitative. It doesn't matter. You can calculate the
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risk numbers in a manner similar to the way Mark is
talking about here or you can make a sort of qualitative
observational type risk assessment where you go out there
and you make observations of what's going on and how it
happens. We tended not to do the qualitative
assessments. As time goes on we get a little bit more
sophisticated in what we do. And we've all got computers
and everything so if you have a computer you want to use
it so we try to do things more quantatively as opposed to
qualitatively. But what it is in essence is an
evaluation of potential for actual adverse affects or
negative type affects on contaminants at a hazardous
waste site on anything basically other than people. It
says in this definition that we don't cover domesticated
species but that is in our regulations. But certainly if
we were going to - we wouldn't - we wouldn't ignore cows
or dogs or anything like that. So if we had - if we had
that as an issue on a particular site we would certainly
take a look at domesticated species. So that's the basis
- the basic difference between an ecological risk
assessment and a human health risk assessment. With an
eco risk assessment we look at bad affects on everything
other than people. So we look at plants, animals, fish,
birds, the whole shooting match. So in essence I think
Mark has a much easier. job because he only looks at one
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(1) thing to value and I look at everything else.
Although I think he would probably argue with me on that.
The next page. Why do we do an ecological risk
assessment? Well first of.all we do it because our
regulations require us to do it. Second of all we do it
because as EPA we are required to protect both human
health and the environment. Some of the reasons - some
of the things that we want to look at in terms of
ecological risk assessment is to help define the extent
of contamination on the site. How much of an area - if
it's contaminated how much of that area is contaminated?
What effects would that have on wildlife or on habitat
that the animals actually live in? What effects? Are
they positive effects? Are they negative effects? We
can look at both. We also want to document ecological
impacts as part of the remedial investigation. I think
- I think there's been some introduction to the Superfund
process. I realize this is not a Superfund site but we
are following some of the rules and regulations of
Superfund. Remedial investigation is one (1) of the
first steps that you do at a site to determine if there
is part - if there lS going to be something hazardous on
it or not. So we do an eco risk assessment and a human
health risk assessment as part of the remedial
jnvestigation. After we've done our remedial
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investigation we have to come up with decisions as to
whether something needs to be cleaned up or not. And as
part of the clean up activities you can in fact impact
the habitats of the animals that are living there.
Sometimes we have to make a decision do we have to cut
down all the trees to save the forest? Now if those
trees are contaminated what are we going to do with them
and by cutting them down we're destroying a habitat too.
So is it better to leave the contamination in place and
not destroy the habitat? Or is it better to destroy the
habitat and maybe save it for later generations or re
plant it or re-vegetate it or take the wetland from here
13 and maybe try to create another one over here? So we
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have to - we do ecological risk assessments not only to
determine whether clean up is necessary but also what
effect the actual clean up activities may have on the
habitat. We also can do an ecological risk assessment
over the long term looking at the animals and the plants
of this particular habitat over twenty-five (25), thirty
(30), maybe fifty (50) years after the remedial
investigation has occurred to monitor whether the
remedial investigation was effective. I don't think I'm
going to be around for the next thirty (30) years or so
to monitor this. I haven't really been involved in this
but there's certainly a potential for eco risk assessment
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to be used in that way. The next page is our frame work
for ecological risk assessment. This is very similar to
the frame work that Mark talked about earlier, the human
health risk assessment. Ecological risk assessment is in
the big box in the middle of the page. It would be nice
if I had my colored slides but I don't. Needless to say
the eco risk assessment itself consists of three (3)
parts; the problem formulation, the analysis phase and
the risk characterization. The analysis phase in the
middle as you see is made up of two (2) different
sections where we characterize exposure and we
characterize effects. That's very similar to the four
(4) phases that Mark talked about in human health risk
assessment. So the frame work where the - the bounds
within which we do an eco risk assessment and the way we
do human health risk assessment are very similar. So
many of the things that Mark touched on I'm not going to
discuss. He talked about no effect levels. We do no
effect levels. He talked about reference doses. We deal
with references doses. So there's many similarities that
I won't go into in detail because Mark has already done a
wonderful job discussing those. So what I would like to
do is go into a little more detail on this box, the whole
thing, the problem formulation, the analysis and the risk
characterization. So if you turn to the next page
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problem formulation, review of existing site data to
define the objectives and scope the risk assessment.
What that really means is that we take a look at the
information that we have now and find out what we have
out there. Are we dealing with a forest? Are we dealing
with a river? Or are we dealing with a lake or a pond?
Are we dealing with wetlands? Are we dealing with a
prairie? Take a look at what's out there. We also take
a look at the past information that we have maybe from
past sampling events, from historical records of the
site. We pull everything together and we try and define
okay what is the scope? What is the total that we're
going to be looking at? Are we going to be looking at
just one (1) area? Are we going to be looking at
multiple areas? Obviously a site as big as JPG we will
probably be looking at multiple areas. So we're going to
be looking at a lot of different habitats in multiple
areas. The next page we talked a little bit about the
elements of a problem formulation. These are the things
that have to be considered when we're doing our problem
formulation. You have to look at what are the
contaminants of concern. You know what is of concern to
animals and plants may be very different than what's of
concern to people. So the contaminants of concern, a
list of contaminants of concern Mark may come up with mav
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be very different than a list of contaminants of concern
that I would come up with. There's probably going to be
a whole lot overlap but the list could be different. so
we go through a processing.in the eco risk assessment to
develop our list of contaminants of concern different
than Mark's list. We also look at the contaminant
release, migration and feed. Mark erased it but he did a
good discussion on that. You've got the source. Maybe
not necessarily on this site but you may have a leaking
drum so you've got your source of this drum is leaking
materials into the soil or it's leaking into the ground
water or it's leaking into the surface water, it's
spreading into the air. How does this - how does the
contaminant go from that source? Does it migrate to
someplace else where the critters could be exposed to it?
Okay? Exposure pathways. How are the critters exposed
to it? How are the plants, we keep saying critters but
we also take a look at plants too. How are the plants
exposed to it? Is it in the soil? Do they take it up
through their roots? De they - is it a burrowing animal
that burrows down through the soil? Is it taken up in
one (1) animal and then maybe a hawk or a fox comes along
and eats that animal and it moves up the food chain? So
there's numerous different ways that an animal could be
exposed tn it. Then there's also the receptors. What
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are the receptors? In a human health risk assessment
there's one (1) receptor. Humans. What are- what's the
focus? With the ecological risk assessment everything
else is a potential receptor. All the plants, all the
animals, all the trees, the birds, the fish, those are
all potential receptors. So we're looking at what
effects may occur to each one of those different
receptors. What are the ecological effects? Do we know
- as Mark said for a lot of the human health scope most
of the human health toxic information is based on animal
studies. So we've got a lot of animal data. We
certainly know - I mean I think everyone knows that
there's a lot of studies done on rats and mice. So we
know how to protect rats and mice. We may not want to
but we certainly know how to protect rats and mice
because we know what's toxic to rats and mice. So
bec~use we know how to protect lab rats we can also take
that information and apply it to any endangered mouse
that might be out in the field. Or an endangered rabbit
or some sort of other mammal that might be out in the
field. Deer, quail, pheasants, all sort of things we
might have out in the field because we have a basis of
some information, a lot of information for - especially
for rats and mice. And what are the end points that
we're looking at? The end points are- the end points
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are essentially the characteristic of concern that we're
looking at. Are we looking at - aY.e we looking at our
reproductive input? Maybe a particular chemical when a
mink is exposed to PCB's for example, polychlorinated
biphenyls - we know that PCB's affect mink. We know that
they're reproductive - they are a reproductive inhibitor
And we know that there's a certain concentration of PCB's
but if a mink is exposed to that a mink can't reproduce.
It doesn't kill the mink but it won't be able to
reproduce. Okay so if you had a population of mink out
on the site and you had PCB's and I'm not - I don't think
you do but I'm just giving you an example on this
particular site, or not on this particular site, but a
general sort of example, because I'm not real sure what
you have out there other than the unexploded ordinance.
But if you had - if you had PCB's and you had mink out
there the adults might be happy. We see adult mink
partying around. They may all be happy and healthy which
for their sake they are, but you won't see any youngsters
coming up. So that would have a population effect
because that population wouldn't be able to reproduce.
So that's the sort of things that we're looking at in
terms of ecological influence. So how do we determine
our contaminants of concern? Well first we look at the
concentration. What 1s the concentration in the soil and
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the sediments in the surface waters? And much like Ma.rk
had but he's erased it, but much like Mark had he looked
at the frequency of occurrence. How often is the animal
exposed to it? Is it an animal that lives here all the
time or is it a migratory bird that spends six (6) months
of the year here and spends six (6) months of the year
down in South American somewhere? So how often is that
animal exposed to it? !s it something in the soil that
the animal is exposed to in the summer time and as soon
as it sn~ws then it's covered and is no longer exposed to
it? We have to take into frequency of the occurrence.
We also look at background levels. Many chemicals
especially metals have a background level in soils.
Arsenic is naturally occurring. Some of the things that
we think of as being pretty nasty chemicals naturally
occur in soil. So how do we distinguish what may be due
to contamination or what may be due to background? It's
always a big concern. Bio-availability. Just because a
- just because an animal is exposed to a particular
chemical doesn't mean it will actually harm it. And the
best example I can think of that is in the atmosphere.
We all breathe in air. We take in air, we breathe it
out. we breathe it in, in and out all day long. Vast
majority of air is nitrogen. Nitrogen is to~ic to us so
we breath~ lD this toxic subst.ancl?. We !neat he it o'"t.
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we breathe it in. we breathe it out. But it's not bio
available to us because the chemical form that it's in in
the air is not a form that's toxic to us. So we have to
go out and look at the soils and the sediments and the
surface water to find out what form of that particular
chemical it's in and see if it's actually bio-available.
Even though the critter is exposed to it doesn't mean
it's in the form that will cause a caustic effect. We
also look at physical properties of it. Is it a gas? Is
it a liquid? And you look at chemical properties of it.
Is it soluble in water, not soluble in water. We also
look at potential for bio-accumulation. Bio-accumulation
means if it gets into a fish and then a Great Blue Heron
comes along and eats that fish, bio-accumulation is the
concept where it goes from the fish to the Great Blue
Heron or from the sediments into a craw fish into a
bigger fish into the Great Blue Heron. So it's a food
chain effect where it may actually - the Great Blue Heron
is not directly exposed to the chemical in the sediments
but it is exposed to the contaminated food that it eats.
So those are all things that we take a look at when we
determine our contaminants and concern. Any questions?
We also take a look at contaminant release, migration,
food, ground water if it d1scharges from surface water.
We look at transported contaminated sediments say in a
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creek or a river. We may have contamination up stream
but if those sediments move down stream we could end 11p
with depositional areas down stream. So it maybe wind up
concentrating it down stream miles away from the source.
So we have to take a look at what is the transport of
contaminant sediments if there is any. Also look at run
off, erosion, as well as leaching. Under certain
circumstances things can leach. Leach in the surface
water or leach in the ground water. And also this is
still under the problem formulation and take a look at
our exposure pathways. And this is - again Mark talked
about this real well. He talked about exposure pathway
in terms of the four (4) components. But what you have
to look at with your exposure pathways is there a route
from the contaminated material to the critter? Or from
the contaminated material to the - to the point? Is
there - 1s there a !ink in this direct connectinn? If
there is no direct connection then you're done. There's
no problem. So you have to take a look at all potential
sources. And again the next page is identification
receptors. And I think I've talked about this a litt.le
bit. A receptor could be a single individual. It could
be a population. It could be a community or an eco
3ystem. In this other handout that T gave you it talks a
iittle b1t about what pop11!atl.ons and coromunit.y ecr_,
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systems are. So if you don't remember your lOth gr~de
Biology as well as the - as well as the rest of us, maybe
you could take a look at this. If not the other thing
too I guess is if you have.any questions I would be glad
to give you my card and my phone number and you could
give me a holler any time you wanted. When we take a
look at an ecological risk assessment alsn we have to
know what are the effects of these contaminants. And
Mark talked about lris and Hiast as data bases. And ~n
the eco risk assessment we also have several data bases.
We've got AWQC is the Ambiavent Water Quality Criteria
documents. The EPA produces a series of documents for -
gosh I don't know - much less than Mark said. I don't
really have a figure. Maybe a hundred (100) to two
hundred (200) Ambiavent Water Quality Criteria. That's
a data base we can draw from. We have other data bases.
There's a data base that's maintained by the EPA at
Duluth which is called a AQUIRE, which is a aqua.tic
to~i~ity data base. We have terrestrial data bases.
There's also an incredible amotmt of informat1on
developed for agricultural resources. So much work has
been done on pesticides. Maybe the agricultural work has
been done so there's - if pesticides are ever of concern
there's a lot of information available through that. You
can also look Rt investigations that we've done in other
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situations. We rated investigations as well as luok1ng
at what I have written down here, structure activity
relationships. That's comparing a chemical structure of
one (1) chemical to another. Say we have a whole lot of
information about this chemical but that's not the
chemical that's on our site. This is the chemical that's
on our site. We want to compare those two (2) and
physically the two (2) chemical structures are all right.
We may be able to make some extrapolations from this
chemical to that chemical. We look a little bit again
about our selection of end points. We have an assessment
end point which is an ecological trait of concern. Say
for instance we have a trout stream and we're interested
in reproduction of trout. That's our assessment. A
measurable characteristic may be the toxicity of a
particular contaminant on trout reproduction. So when
we're doing the eco risk assessment we always come up
with an assessment end point and a measuring end point.
What 1s our concern that we a~e trying to protect? ~rout
reproduction. And how can we go out in thP field and
measure what's going on with the trout reproduction 1n a
given situation? So we've got an assessment end point
and measurement ~nd point. So the ultimate purpose of
problem formulation is to identify the preliminary
objectives. O~ay. We'•re get thro~gh all this at t~is
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point. That's JUSt the fJrst bcx. Okay. We ~orne u~
with problems - we come up with a problem formulation.
We've got the scope. We know what we're going to do
after completing the problem formulation. In fact I
would like to say too is that this process is to get more
information. We may go back and up date some of this
previous information that you have with the new
information. I think on this- on JPG we have one (1) or
two (2) phases worth of sampling out there. So if we do
an eco list assessment after phase one (1) and we go back
and look at it again after phase two (2) there would be
additional information and this could present changes.
So this whole process is - I don't want to say circular
because it's not circular, but you can go back and take a
look at updating the information so you can decrease the
uncertainty.
MR. KEN KNOUF:
Brenda? I guess the question I have
is is this a process that n~ver ends once it beg1ns?
MS. BRENDA JONES:
Well that's why I didn't want to say
it was circular. I probably should~'t have used that
word. WhAt it- ,+ certainly has an end. It is a finite
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process when you can - when you have enough information
to make a decision with an uncertainty level that
everything is moving. There's always going to be
uncertainty associated with decision but you're not going
to be able to make a final decision where everyone -
every bit of information is known. So at some point
they're going to be able to make a decision and there's
enough uncertainty associated with that that everyone can
still look at that uncertainty.
MR. KEN KNOUF:
Now would the focus of this effort be
south of the firing line fence in the cantonment area?
Or would you sometimes expend your effort north of the
fence? How wou}d tJXO temper your - your approach here?
MS. BREND~ JONES:
You know as far as - as far as my
knowledge of the gate it's been primarily south of the
firing line. I guess I would defer to Karen as to answer
the question as to whether - where it rnlght fall an•i
mi9ht be north of the firing line.
MS. ~AREN MASON-SMITH:
I think th•t answer is up to funding
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MR. KEN KNOUF:
Funding?
MR. PAUL CLOUD:
No it actually has to do with the
fact that the property Bouth of the firing line is the
focus because it's being made available for public re-use
and r~developrnent whereas the property north of the
firing line does have contamination and the Army is gojng
to retain that property title that the effort there js
not presently planned for.
MS. CAROL WITT-SMITH:
And may I add to that also north of
the firing line it depends too on both the EPA and DOD
are going through this massive rule making process right
now. The EPA is using the munition~ rule and the DOD is
using what is called the range rule. And this is go1ng
to be the new way of regulating areas like north of the
f1ring line where there is ~anges that are inactive or
closed and how it's going to be managed. And there will
be - eventually once the two (2) rules fall out - some
sort of risk assesswent type of process of the
investigation that will make a judgment on what to do
with these areas. So the ott1er things that you do get
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involved in is w1th the closure activities, the reg1tlate•i
unit, either north or south of the firing line. If you
are attempting to clean close something then you
automatically do the human and ecological risk
assessments to get closure and establishes part of your
clean up numbers if you decide not to go all the '4ay on
the background. But if you decide to close in place and
you are kind of keeping into more the using it as a
landfill. So you don't necessarily have to go through
the full risk assessment for if you're closing the plac~.
but what you may have to work at is what kind of impact
the construction and maintenance of that landfill would
have to be an impact on human way of life.
MS. KAREN MASON-SMITH:
I was just wanting to say too I think
that still funding is going to be a big issue.
MR. PAUL CLOUD:
Funding is part of it but I don't - T
don't want anyone to misunderstand me that the Army is
not intending to do anything north of the firing line.
As Carol from the ha~ard waste branch of the Region 5 EPA
has said ther~ are thes~ two (2) rules that are in ~he
process of ccm1ng o•1t. On..:- (1'~ is EPP-.'s rule a~:d th~
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other i& the DOD's rule. At a futur~ date, hopefully
this year, but I don't have any guarantee on it, hut whe1~
those rules are final and everyone in the agency, the
EPA, the DOD are satisfied.with that, I would expect that
Region 5, the State IDEM and the Army will get together
to discuss what types of actions are appropriate north of
the firing line. An example might he instead of clean up
we might erect like in the open detonation area north of
the firing line by the Air National Guard area, we might
erect some type of erosion control. Put some hay b~les
down at the bottom of the foothill by where the street is
so that any run off from water that would rain onto there
and wash the explosive residues and the heavy metals into
that stream and then ultimately get off the property
would be contained. In addition to that we may erect or
install a number of monitoring wells around the perimeter
of the Proving Ground to monitor for the explosives and
metals and depleted uranium. And use that as a basis to
say okay we're sampling right now. We have no
indication, no elevated levels of any of these materials
are coming forth right now. We don't believe there is ~
reason to go do anything more. But as we continue to
sample basically forever as long as we own the property,
if we get an indication that there is an increase in the
levels of thP materials then thet would prompt us to do
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something else whether i! wouid be removal of the
contaminant or some other erosion control mechanism. So
I don't want anybody to think that the Army is never
going to do anything north of the firing line. It's just
that that is not the primary focus right now. We're alsn
waiting for these other rules. There is a funding issue
that would be factored into it. And it's factored into
it because north of the firing line is such a large area
and it has such a heavy concentration of UXO and deplet~d
uranium. But it's not to say that the Army will not do
anything. That is not correct. So don't walk away from
here thinking that north of the firing line the Army will
never do anything.
MS. BR~~DA JONES:
Any other questions? Okay. That
really was the tough part. The problem formulatiou is
the basis for the whole eco risk assessment. There'~ a
lot of information that I threw at you. ! think th<-L the
20 most important thing to realize is that once you get the
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scope of your analysis set up, once you know exactly wha~
you are going to do with it, that kind of falls in place.
We can go through the rest of this fairly quickly. The
next part is the erposQre assessment where you look at -
try to characterize the contami~ants nut therP. Exactly
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what contaminants are there and what concentrations are
they at? If you go through the receptor
characterization, once you've chosen your receptors you
have to determine where are they on site? And you go
through some of the same sorts of calculations that Mark
talked about. We talked about the frequP.ncy of
occurrence. We talked about the duration. We talked
about area, use factors. in terms of for example I us~d
the Great Glue Heron before. The Great Blue Heron may
have a feeding range of several hundred acres. But
you're only looking at a site that's a half an acre. So
how do you take that into account that this Great Blue
Heron may be feeding on this whole area and your site is
only a small portion of its feeding range? So those are
the sorts of things that you look at in exposure
assessment. You come up with variables for that. And
then you look at your ecological eff~cts of the
chemicals. There's a lot of different ways you can do
that. You can go to the Jjterature and look at the
information that's in that literature or you can go out
into the field and you could look at all the specieP that
are there, what's the diversity of those species? Are
the species that are present are they typical of a
!?Olluted area? Are they typically found in clean areas?
You can do all sorts of community structurE> analys1s
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Are there a lot of adults? Are thete a lot of this
particular species compared to that particular species?
You can also go out there and collect individuals and
look at their tissues, look at their liver development,
look at their - you can go out and do all sorts of things
depending on what particular contaminant {s that you're
looking at. You can do toxicity testing. You can take
the soil back into the laboratory. Or you can take the
sediment back to the laboratory and expose the critters
in the laboratory to those soils or sediments directly
from your site. There are a lot of different wayA that
you can come up with your effects information. So you
combine your effects information and your exposure
information to come up with a risk characterization.
Basically the risk characterization is what is the
ecological significance of everything you've been doing?
Do~s it mean anything? Is it going to have an effect <Jn
the individual? Is it going to have an effect on the
population or the community or the eco system? ll_nd what
sort of effect is it going to have and what does that
effect really mean? Is 1t something that is harmful
enough to cause a clean up or to take a look at some sor.t
of a clean up type activ1ty? Or get it? Or can we get
to the decision of we want to destroy the habitat to save
it? Do we w~nt to dig ~P a wetland, contaminated
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wetland, to save that con•am1nated wPt!and? Thos~ are
hard questions that we have to answer. And thos~ are the
things that we deal with in terms of risk
characterization assessment. So you pull together the
exposure and the effects data and take a look at what is
the ecological significance of that risk
characterization? Also in the risk characterization Mark
talked quite a - Mark talked - talked about uncertainty
analysis. Everything that we do there's a lot of
uncertainty. We don't know things for sure. We're
making extrapolations from one (1) species to another.
We are making extrapolations from laboratory studies to
field studies. All sorts of good things. So we have
some uncertainty associated with that. That uncertainty
is something that we have to live with but we also have
to state it in a document. What are the uncertainties
and \>lhat are the assumptions that we gave and what effect
do those uncertainties actually have on the decisions
that we make? Finally we try and describe the risk in
terms of - terms of what does it really mean in the real
world? We can come up with whole table after table aft@r
table of numbers but what does it really mean in our
work? Where does an eco - these last two (2) slides
I have I just wanted to review again. Where does an ecc
risk assessment fall 1nto the proce~s? We ~an do Jt
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during the remedial investigation phase. You can do it
during site characterization. You can do it during your
analysis of different clean up alternatives. You can do
an ecological risk assessment while you are designing
your clean up a~tecnatives. You might also do an
ecological risk assessment after you've don~ a clean up.
Like I said earlier you could do that to determine how
effective your clean up was. Did your clean up actually
remove the contamination and remave exposure? So there's
a number of different points within an investigation
where you can do ecological risk assessment. And the
last page again is a - is a copy of the first one is why
do we do an ecological risk assessment? One (1) because
EPA has tasked us to protect both human health and the
environment. But we wanted to find the extent of
contamination and we want to estimate th~ effects on the
wildlife and th~ plants and the ~nimals that are now
living out there. So that was - that was a lot. And I
thank you all for listening. If there are any questions
I would be giad to answer.
MR. TIM MOORE:
What - w~'ve listened to the way the
EPA studies and gathers infcrmation. But what - what
invcl•rement is the EPA been inv~lved jn JPG? w~ know
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that the Fish and Wildlife Service has been involv~d in
some studies, did an environmental impact study wJth them
and the EPA. Where are we at? You have shown us how to
gather this information and what to do with it. Is
there anything that amounts to the EPA at Jefferson
Proving Ground?
MS. BRENDA JONES:
I can't - an environmental impact
statement is something- that's a little hit different
than what I talked about. This is an ecological risk
assessment. So I can't actually speak to an
environmental impact statement. I don't - I would have
to defer to these guys (indicating). In terms of the
ecological risk assessment what I've had involvement in
so far is there are I think eighteen (18) sites south of
the firing line? I'm not sure.
MR. PAUL CLOUD:
MS. BRENDA JONES:
Fifteen (15) sites south of the
firing line okay where we have doce a preliminary risk
assessment on. And all the preliminary risk assese~ent
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does is that it kind of screens out sites that we know
aren't a problem. And makes us take a look at these
other sites saying okay we have to take a look at these
to see if there really is a problem or not. So that's
where we stand right now as far as my involvement in it.
I would have to defer to these guys to see if there is
any other work. That's all I've been involved with so
far.
MR. TIM. MOORE:
Okay. So you've been involved to 3
minor degree so far?
MS. BRENDA JONES:
Well on the eco risk assessment yeah.
MR. PAUL CLOUD:
Brenda is a technical expert in her
field. People like Karen and John and I are more
general1sts that have a lot of in~0rmation - a little
information on a lot of things. Brenda has a lot of
information 1n one (l 1 focus similar to Dr. Jones
(Johnson). And W?- because we are the decision makers
as to ~hat would be acceptable on levels we will clean up
to rely on the~r te~hnica! @Xp•rtise 1n thPir area~ r1f
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<;>Y.pertise to pt ov1de us w:i th intorrr.at i rJn +.hat we .,~ ll
need to be able to come up with what levels are
acceptable tor that portion of the Proving Ground we will
clean up.
MR. TIM MOORE:
Yet to me characterizing it as the
environmental impact study or ecological risk assessment
is splitting hairs.
MR. PAUL CLOUD:
Well it's kind of like talking about
oranges and forts. I mean they are not even the same
thing. ~n ecological risk assessment evaluates the risks
for everything other than human essentially. Wherea~
environmental impact statement addresses what will - wha.t
are the potential consequences of an action that the
federal gave~nment would like to take? ~nd specif1cally
there was an environmental impact statement done for th~
disposal and re-use of JPG. It came out in December of
1995 and that evaluated a medium, a light, and a heavy
industrial re-use development to use as a standard, just
a care taker function where nothing was ever done, ,::>,nd
that's mandstory reference backaround to help evaluate.
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into a numbPr of different studied areas based on
potential levels of re-use light, medium and heavy
industrial and how that might affect the environment in
those areas. That's what environmental impact statement
~s. And thos~ - if any of those levels of re-use are
unacceptable then you can either not do them or you might
have to do something in addition before you could do a
certain level of re-use at JPG. Maybe that ~xplains
environmental impact statement a little better.
MR. TIM MOORE:
Yeah I realize it.
MS. BRENDA JONES:
Any other questions? Yeah?
MS. DOTTIE REINDOLLAR:
Does anyone have the key for this
ouilding to lock it up?
MR. PAUL CLOUD:
I have a key. I always take out a
key for the night that we have our meetings.
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MS. BRENDA JONES:
Well that's two (2) questions I can't
answer. Anybody else?
AUDIENCE MEMBER:
Brenda you said an effort is being
done at thi& lnstallatinn and other facilities that Are
open. Or is it always closed type of facility?
MS. BRENDA JONES:
Carol is shaking her head no back
there. I personally don't work on open facilities. I
have only been involved in Superfund sites with base
closures.
MS. CAROL WITT-SMITH:
hny human and ecological risk
assessment is done basically in the RCRA program where we
deal with hazardous waste. That's reA!ly ~ny time a
corrective action is proposed we automatically as part cf
this investigatcion process have to do nne (1\ of these.
It might be a very simplified one (1) or it might be an
elaborate one (1). So then the level of detail depends
on the contamination at the individual site. But it is
also - it has to be done not only at the ahandoned or
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Superfund type of s1te but it's also at operattng
facilities. And one ( 1) close by is Naval Center at
Crane, Indiana. We are actually doing two (2) human and
ecological risk assessments going on right now at ten
(10) sites. And we are in the phase of beginning one (l)
and we have another one (1) that we are actually doing
biological substance work. So it is part of even the
process of not only looking far contamination at sites
but it's now leaning toward actual operational issues
like if you have an incinerator and want a permanent
incinerator. It's now becoming a human and ecological
risk assessment portion to the incinerator. In order for
you to get a permit to operate you would have to go
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impacts as how someth1ng might affect the environment.
MS. BRENDA JONES:
Three (3) for. three (3). I didn't
19 answer a single question. Anything else? It you h;~v., -
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if you have Any questions like I s~y that one (1) h~ndaut
that I had I think gives a good background on ecology
And I'd be happy to give you my card after the meeting if
anyone wants to step ~nd b~ able to call my office 1n
Chicago. Thanks.
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A-PPLAUSE )
MR. PAUL CLOUD:
In addition to Brenda's card I have
left a number of my cards I recently had printed up. If
anyone would like to take one (1) of those! encourage
that. If there's not enough there I have gi,ren Ken
Knauf, our site manager, an additional number they can
pick up at the Proving Ground. If you would like to get
one (l) for one of your friends it does have a toll free
number that you can get ahold of me in Maryland if you
have a question and would like to raise an issue, have
something you would like to see on the agenda. So don't
feel bashful if you don't want to bring the issue up
here. Take one (1) of my cards and you can give me a
call. There is a toll free number. You just dial it and
then ask for one (1) of the extensions and they will
route the number to me. If I am not there you can leave
a message on the voice mail and I can get back to you
that way. As part of that effort for improved and re-
1 ook at our community relations plan that the hrrr.y has to
keep the community informed and involved with the
envi ronmentaJ clean up of the Proving Ground, back in
late 1994 in Flugust we had our contractor with the Army
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interviews with the citizens. And ~s a result we use
that information to generate what's called a CRP or
Community Relations Plan. And it's now called a
Community Involvement Plan. That was a plan that came
out in early 1995. It's now early 1997 and the Proving
Ground has b~en closed for over a year. And the Army has
discussed the issue with the EPA and the State and we
believe it's time to go revise the plan. And I would
like to introduce Ms. Corrine Buoni from SA!C who will
now give you a brief overview of where we're going to go
with this revised Community Relations Plan. Corrine?
MS. CORRINE BUONI:
As Paul indicated my name is Corrine
Buoni. That's my real name. I go by no other aliases.
Unfortunately ! was not able to get a poster made and
th~refore I'm net subject to the use cf the overhead
projector tonight so I'm going to try and walk you
through what we're going to be doing over th~ next few
months for the Army. But first l~t ~~ take a sid~ steo
here. This will 5ort cf set the frame w~rk for wh~t we
are going to he doing. Maybe. As Paul indicated the
Army came out with the Community Relations Plan in '95
to b9.sic3lly set O'tt the r>.rmy's plan for keeping the
public 1nfor~ed a11d iJlvo\ved in the activjti.es
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associated with the closure of JPG. Jt had two (2)
basic objectives. One (1) to inform the community on
all the activities and plans for. closure of the
installation. And second.of all to obtain input into
the Army's plans and activities and decisions regarding
what to do ~ith the land and how they should proceed.
By community we m~an the local residents here in the
City of Mad1son, the county officials in the three (3)
counties that encompass JPG, the media, feder~.J and
state regulators, community groups, environmental
groups. We're meeting the collective sum of
organizations and people that are involved or impacted
by the activities of JPG. This plan came out in '95
although that doesn't mean that activities are not going
on prior to that time. What my company is going to be
doing in suppot"t of the Army is updating this plan to
insure that it's being responsive to the community's
needs. Now to date the community has been involved
through prim~rily the R~storation A~vjaory Board
pro0ess. To a much mor~ limited ~xtent there have been
media updates, press releases, fact sheets released and
perhaps there may have been a few community group
reaching type activities. But primarily to date the
Restoration Advisory Board has been the primary
mechanism for inform1ng the public on what's been going
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on at JPG and for getting input into the process Nov
we are at a juncture we're going to try and see where
are we today? Are we doing a good job? Given to where
the installation is in the closure process do we need to
adjust the plan? So this is the opportunity for you as
a community to provide input as to how well the Army is
doing in terms of informing the public and then taking
input into the decision making process. Over the next
month and a half or so, probably February or March time
frame, weather permitting, we will be coming out here to
the installation and conducting a series of interviews
with the community. We're going to begin with a list of
people that are included in the community relations
panel, I think it's about a hundred (100) folks that
have expressed an interest in the past to be informed
and involved for the closure process. We will start
with that list and try to weed them out and try to
identify as large an audience as possible to interview
and get their input on how well we've been doing. If
any of you tonight wculd like tn particularly be certain
that you're called out please give me a call. We woulrl
like to get you involved. But basically we will be
going through an interview proce~s for about four 14) to
six ( 6) weeks in cornbinati•:m of course interview and a
te} ephone call. A.nd then we ...,ill take str.:r.Y. ol' ~<~her:"! ·-~~
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are and what we've learned a11d try to reshape the
program in response to the community needs. ~nd
probably come out with a plan within two (2) months
after completion of that activity. So we are looking
probably May t1me frame we are going to draft thi~. Do
you have any questions?
MR. TIM MOORE:
Your plan will do what? A plan to
accomplish what?
MS. CORR.INE BUONI:
Basically to you know make sure that
the community is informed as to what's going on with
closure process in terms of for instance I believe you
have asked questions about what is going on which in
te~ms of the site is risk assessment and the clean up.
So that to me says we're not doing a good job. So mayb~
you might have some comments in how- how can you tell me
more of what's going on? This may not be the only form
that WE! communicate. Maybe there are other ways that we
can do it, We would like to get your ideas. Also do you
feel like you have an input and a say in the process? Do
you feel lik~ your questions are be1ng answered? So
tbnse are the k~'lcif- of things that that plan will
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address. Yes?
MS. LAURA HODGES:
I'm a little puzzled about in the
center section there about how th~ community 1s Cllrrently
involved in JPG? I'm a member of the media. The second
point says media update and informing the public about
8 closure progress and upcoming meetings? Is that - are
9 you talking about press releases that go to the media or
10 are you talking about what the media is doing?
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MS. CORRINE BOON!:
No, no, no. This is - this is the
14 Army's way of getting to you folks on what's going on in
15 terms of when the meetings are and things of that nature.
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MS. LAURA HODGES:
T do get notices of the meetings but
I don't remember at any time during the past year getting
any informat1on aside from the agenda.
MS. CORRINE BOON!:
You are probably correct and as I
24 sa1d these are very limited to date. These are the
25 me~hanisms that - these have been limited access.
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- 1 MR. PAUL CLOUD:
2 Since the Proving Ground has closed
3 the number of press releases have basically fallen to
4 zero. That was one (l) of the factors that we considered
5 when we talked with the State EPA to advise them of the
6 Community R~lations Plan. Maybe that's something we need
7 to come out with on a roore periodic basis ~ow. Even if
B the Proving Ground :i.s closed does not necessa t:i l y mean
9 that we shouldn't come out with periodic press releases.
10 Whether that's a fact sheet and memo or in the form of
11 press release or some other type mechanism. So I do
12 understand that since the Proving Ground has closed that
13 particular method to get information out has not been
14 used.
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16 MR. DAVID NOVAK:
17 I was wondering when or what the
18 status is of an agreement with the U.S. Fish and Wildlife
19 in terms nf the north sector of the Proving Grounds?
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21 MR. PAUL CLOUD:
22 That - that agreement is currently
23 with the Fish and Wildlife Agency. We, the Army, signed
24 a letter and provided it to them for review just before
25 Christmas. December !6th if I'm correct. We t~lked with
., '
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Fish and Wildlife yesterday. They are contjnuing thejr
review. We expect some comments back shortly. They have
stated to us that they see no show stoppers in that
agreement. What that agreement essentially does is to
provide a funding mechanism from the Army to the Fish and
Wildlife to provide s~me additional man power from the
Fish and Wildlife for the Fish and Wildlife to perform
natural resource functions north of the firing line.
There are some specific comments that they are going to
make and it's basically a detailed type of thing that
will probably result in two (2) things happening -
actually three (3) things happening. One (1) a meeting
between the Fish and Wildlife Service and the Army to
work out details. Two (2) to get those details
incorporated into a revised memorandum of understanding
and then three (3) to have the actual und~rstanding
signed by Commanding General at my headquarters and the
regional administrator who I think has delegated that
authority now to one (l) of the field officers. We
expect that probabl~ in light - was that Mar~h. ~pril
t1me frame? We don't know. We are hoping to have
comments by the end of the week. So we are proceeding nn
along those lines. Again the Fish and Wildlife Servic•
did t~ll us yesterday they s~w no show stoppers in the
o;:-igina] proposal we harl pc•."lVlded to them J'-l<<t befcr.e
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Christmas.
MR. CLYDE CAMPBELL:
How much acres does that involve that
the Fish and Wildlife is talking about?
MR. PAUL CLOUD:
That area is north of the firing
line. For basic purposes it's fifty-one thousand
(51,000) ac:re.s.
MR. CLYDE CAMPBELL:
That's above K Road?
MR. PAUL CLOUD:
No that's above the firing line.
That's from the firing line north to the north perimeter
from the east and the west.
MR • CLYDE CJI...MPBELL :
Okay above K Road how much
contaminant is in that area up through there?
MR.. PAUL Ct.OUD:
T~at is al! potential DXO.
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MR. CLYDE CruMPBELL:
~bove the R Road?
MR. PAUL CLOUD:
Yes sir. The~e was what's called an
archive search work done by the Corps of Engineers that
came out in June of 1995. We have copies of it at the
8 Proving Ground. There is a copy of it at Hanover College
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in the Administration - Administrative Record that we
have established there, that the company established for
us. You are more than welcome to take a look at that.
It will go into some level of detail. It's broken up
into three (3) volumes. One (1) is south of the firing
line. One (1) north of the firing line to K Road and
then one (1) volume north of K Road. It will go into
some lengthy discussion. They went through archi••~
17 searches. They went through overhead aerial shots. They
18 went through personnel interviews. They went through the
19 firing records at the Proving Ground. It was a very
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intensive effort that lasted about six (6! months.
MR. CLYDE CAMPBELL:
Thank you.
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MR. PAUL Ci.OUD:
Yes sir.
MR. JOHN HOLMES:.
On this memo ot 1mderstanding l•lent to
the State Wildlife in December --
MR. PAUL CLOUD:
F1sh and Wildlife. Federal. Federal
agency.
MR. JOHN HOLMES:
Federal agency?
MR. PAUL CLOUD:
Yes fli!'.
MR. JOHN HOLMES:
Ts that document available for our
review?
MR. PAUL CLOUD:
We can provide a copy but it's not
final yet. This is a forwal agreement between two (21
f~deral agencies. Once the document has been signed we
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will be glad to provide you w1th thP record but it's
between two (2) federal agencies right now. It is not
final.
MR . JOHN HOLMES:
Well I - I would like --
MR. PAUL CLOUD:
Again let me - let me emphasize the
intent of this document is not - Fish and Wildli~e will
not take title to the property. All the Army is doing is
utilizing the Fish and Wildlife Service to basically do
what they are normally tasked to do. But they don't have
the work that we would like to see them do north of the
firing line into their budget cycle right now. Normally
it takes about three (3) years to get a new item in the
federal budget, federal agency's budget cycle. So part
of that agreement is that we, the Army, will fund the
Fish and Wildlife and I believe it's for approximately
three (3) to four (4) people per year for the n~Kt three
(3) years until they can get it in their funding cycle.
And then it will be their funds instead of the Army's
fund that will dn this. And it will basically provide
three (3) to four 14) Fish and Wildlife people to perfor~
nat~ral resource proteotion ~unctions north of the f1rin~
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line. They w::.11 not nsEume any other tunct1ons or
responsibilities. They will not mow the property. They
will not have any liability for the property.
MR. JOHN HOLMES:
The thing that I find disturbing and
I will admit that I'm new kid on the block in relation to
this program, but the thing that I find disturbing
representing a county immediately to the north that has a
significant stake in this property and probably has under
its boundaries the largest portion of the land area
covered by this site where there is a lot of historical
frustration as to how the government took this land over
to begin with many years ago down to the present time.
That th1.s whole effort seems to be centered in a
community to the south with little consideration of the
governmental officials in that county that is north.
MR. PAUL CLOUD:
Let me give you a little history,
maybe repetitious to some people here, but as you've
already said you are new to the process. Let me give you
a little bit of history on how we arrived at the property
rP-use stage that we currently are at at JPG. When a
facil1ty, a milit~ry f~cil1ty, ~as identifiPd for closure
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1 under the BRAC p~ocess JPG was in the first round in
2 1988. There was a round in '91, '93 and '95 as the most
3 recent. When JPG was identified in '88 part of that
4 process that is required tor re-use of property goes
5 through a - what they call pro~erty screening sequenc~ or
6 process for making that prop~rty available. This is
7 required by law. But what it basically says is that the
8 first entity or group that the property is made available
9 to - and in this case it's a military facility - is
10 another military organization whether it's Navy, the Ai~
11 Force, the Marine Corps. They are given first cut to see
12 if they want to take the property over and then it would
13 be a federal to federal transfer basis. The Army had it
14 and the Air Force has got it. Now they've got to assume
15 the liability. No one in the Department of Defense
16 raised their hand for that. The next group that it comes
17 available for potential is any other federal agency.
18 There was a federal agency that did in fact write a
19 letter. I have a copy of it if you would like to 5ee i•
20 It's signed by Secretary Babbitt, Department of the
21 Interior. It's signed back in April of '94. They raised
22 their hand and said we are interested in approximately
23 fifty-three thousand (53,000) acres. Not only everything
24 north of the firing line but segments down south of the
25 f1ring !ine. As tha~ process went ~nd developed o•rer th~
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next six (6) months to a year, it became clear to the
Fish and Wildlife Service that yes they were interested
in the property but because there are significant
concerns in their· agencies .few were liability for UXO.
The depleted uranium that they determined - this was
totally in their house - that they did not want to tak~
title. Based upon that fact the government then w•nt -
the federal government then went and said okay we - the
federal government declared everything south of the
firing line as ''excess''. Now it can be offered t0
states, local communities and even private individu~ls
should we get to that step. The next step was to make
the property available to the state. They are given a
certain amount of time to make their desires known. No
one from the state raised their hand. The next
opportunity is for the local community, the counties as
it were. For the count).es to makP. t.heir request they had
to create what's called a Local Redevelopment Agency or
LRA. That LRA was in fact cr~ated here. Becau~..- the
federal government made onlv the area south of the firing
line as excess and all of that property is in Jeffer~on
County, while the LRA was - Jefferson County was granted
primacy by the other counties. The other counties had
representation and participated in that LRA and in their
request for the property. They did in fact submit a
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request to the Army. That request was in fact denied
based upon financial considerations, based on the fact
that they were asking for the property and they were also
seeking unsecured and unguaranteed loans or grants from
the federal and state governments when they had no
assurance that that money was going to be provided and
that they were - they had no other mechanism to assure
that their plan h~d any economic liability to get those
funds that weren't provided. So that app1ication was
denied. The next process was that property was put up
for bid. The initial bid process went through the Corps
of Engineers who did an appraisal of the property. They
established what they considered was a fair market value
minimum of six million ($6,000,000) dollars. That went
out. We got no offers as a minimum of s1x million
($6,000,000). After that we decided we would try it
17 again with no minimum bid. We went through that Pt'Ocess.
18 We received a half a dozen bids accepting the high bid
1g from Mr. Ford of Ford Building and Lumber of f1ve p0int
20 one lS5.1J million dollars. And that's how w~ ha~e
21 gotten to the process. But to say that any of the other
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counties did not have a role, did not participate and
were not knowledgeable about the LRA and the
participat1on and re-use is not really oorrect. Rut J
think if ycu go back ~nd H~P th~ Pr•)c~ss and ha~ 1t
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d~veloped and what )t be.d to go through- and this r.ot
only applies to JPG but to all closing facilities, then
that is the sequence. Then there is a definite hierarchy
on who has priorities. The homeless are also factored
into that. In fact they take priority over just about
anyone. But if a homeless organization would have com&
in and said we want to go take the housing units of the
JPG and they had a financial sponsor to make that viable,
it would take precedence over just about anyone. You
have to go through that process. No homeless provider
came forward. But we would have to go through that
process to get to this.
MR. JOHN HOLMES:
Just for point of clarification. hre
you saying that the County of Ripley did not in •:.he
appropriate time table make a statement as to their
wishes and wants and desires?
MR. PP.UL CLOUD:
No I'm not. The County of Ripley did
in fact make their wishes known. They made it known
through the LRP.. And they also made it through the
Jefferson Proving G~ound Redevelopment Board when it was
in ex1stence before the LRA because they participated ~r
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that even before I became associated with JPG in 1994.
So Ripley County has been involved with the redevelopment
and re-use of the Proving Ground since the Proving Ground
basically was put on the closure list and a redevelopment
organization was in existence, whether it was the LRA or
before that.
MR. JOHN HOLMES:
But they weren't privileged to create
their own redevelopment board?
MR. PAUL CLOUD:
They did in fact. The Army had no
directions that said you, you and you will be on the
board. They asked for members. T~is was a total
comm\rnity board. There WPre - the ccmmandin~ officer was
ex-officio member, i.e. he was granted status to come on
the board but he was not a voting member.
community run, community controlled. Yes ma'am?
meeting.
questions.
MS. JAE BREITWEISER:
I missed the first part of your
1 had a previous me~ting. And I have some
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MR. PAUL CLOUD:
Sure.
MS. JAE BREITWEISER:
Concerning the Fords' purchasing of
the land that they have and own, I understand that you
made that announce~ent that they are asking for forty
t40) acres to be released? Is thRt correct?
MR. PAUL CLOUD:
Let me make the clarification.
MS. JAE BREITWEISER:
After you do that I have some
questions.
MR. PAUL CL.OUD:
Sure. Well let me make the
clarification first. Currently Mr. Ford and l:is company
OW!1 no prope-rty.
MS. JAE BREITWEISER:
I know that.
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MR. PAUL CI.OUD:
It's a lease and furtherance of
conveyance.
MS. JAE BREITWEISER:
I know that.
MR. PAUL CLOUD:
Until such time as either the UXO is
removed or the environmental contamination is cleaned up
or we identify areas where that is not an issue, we have
not transferred anything. There is a forty (40) acre
parcel commonly referred to as a parcel that's bounded by
Woodfield and Paper Mill Road and Mr. Ford has expressed
to us a desire to obtain actual ownership of. We are in
the process of creating that document and it's my intent
as the Army's representative to provide to, not only the
State and the EPA. but all the RAB rnembers and anyone
else in the public who would desire to see a copy of it,
what's called a finding of suitability to tr~nsf~r, ?
FOST. Th1s is an environmental document that explains
what basically is being proposed to transfer and if there
is any environmental consequences of that transfer. Is
there lead based pa1nt in the hujldinqs? Is th@re
asbestos ~n the builrlinq2? Do ~e have contaminat•d sol>
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contamin<~tecl grmmd water? What's the adjac-ent properly
look like? Has there been a radon survey done? Does
there need to be a radon survey done of the buildings?
So on and so forth. And then that will go out we ar~
hoping either in January or mid February to have that out
for a thirty (30) day review. It comes back. We look at
the comments and ~ry to incorporate everything we can and
it goes out for a shortened review to identify those what
we call outstanding issues, things that we didn't
incorporate but if we identify that as an outstanding
issue then we would attach that to the back of the
document so that it's just not thrown away and ignored.
I mean it becomes part of a public record. It would then
go up and be signed by the individual that has that
authority and it depends upon what is present at the
property. In this case the person that's delegated th~t
authority is the command above my command which is the
Army Material Command in Alexandria, Virginia. They sign
that document. They signed the document for building 216
and the railroad trackage. That was signed at AMC, Army
Material Command. Once that document is sjgned it would
then go to the real estate division of the Louisville
Corps of Engineers as the Army's real estate agent
essentially. They will then cr~ate the deed transfer
documen~ ir,cotp~rating parts of the FOST &a ne~essarv if
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there have to be deed restrictions, historical prov1sion~
that may have to be complied with, things of that nature.
That would be rolled into the deed. The deed would then
be signed by the Secretary of the Army or his designate
and then it would go to the successful person, 1n thim
case the forty (40) acres, Mr. Ford. And in the cas~ of
the Madison Port Authority, the Madison Port Authority
signed and they paid their sum of money and now they are
the first in fact title holder of property that used to
belong to the Army.
MS. JAE BREITWEISER:
Do the Fords have to in any way
announce to the community what they are doing with that
property? Is there any agreement between them and the
gov~rnment that they do that?
MR. PAUL CLOUD:
No there's not.
MS. JAE BREITWEISER:
Does that go back --
MR. PAUL CLOUD:
And there's no requirement for th~~.
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They are private - not only private individuals but th•v
are private corporation for that matter.
MS. JAE BREITWEISER:
So the community will never know what
they are developing unt1l it's done then unless it goes
back to local zoning?
MR. PAUL CLOUD:
If they want to do anything that
would require zoning then it would - it's my
understanding that they would have to come to the council
and get that ~oning for whatever they wanted to do.
MS. JAE BREITWEISER:
Well that presents a problem. Our
county doesn't own that so how can they have rules and
regulations for zoning on that land?
MR . PAUl. CLOUD:
No. But what Mr. Ford would have to
do is at the time that he becomes the owner if he wants
to do something other than what's currently there, i.e.,
light industrial, medium industrial, residential,
something that wo~lct require a zoning change it would be
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his responsibility to seek that with the county and fnr
the county and Mr. Ford tc come to an agreement. 'l'hat 1.s
his responsibility.
MR. DAVID NOVAK:
Paul? Just a quick question. When
he takes possession of the land, when he finally ends up
buying it does it lose it's status as f~deral facility
property?
MR. PAUL CLOUD:
Well whatever portion that he takes
title to that is an accurate statement.
MR. DAVID NOVAK:
So that then it reverts to a county
status of sorts?
MR. PAUL CLOUD:
Let me make on~ (l) clarification on
- on that because you've rais@d an interesting point.
And I hope this doesn't confuse everyone. In 1997
Defense Appropriation fnr the D~partment of Defense had a
change in the Superfund law. In it it said before this
time, before ~his law was p~ssed 1n ~ate '?~. bMfor~ th~~
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law Wa5 pass~d yol• ~o\alci ~ot transfer property witli
environmental contamination on it. This 13w made a
change to that. It said yes you can transfer property
with environmental contamination on it but in the case of
a Superfund site it had to get Pegional Adn,1.nistr<ttor's:.
concurrence from the EPA. In the case of a non NVL ~ite,
which is JPG's case, you had to give the governor of the
appropriate state, in this case it would be the governor
of Indiana. Before the governor of Indiana is going to
re-allow the Army to transfer any property to Hr. Ford,
he's going to have to receive some assurances that the
Army is not going to walk away from the property. And
that is also written into the new revisions of the law.
It would require the Army to provide schedules and
commi. tments based on availability of funding that we will
continue to do the clean up. What it does is allow
property to be transferred because what has been
experienced from lessons learned based on base closures
in other areas of the country is that for redeve-lopment
it's very difficult for a company to ~et a bank loan for
property that they don't own. So if Mr. Fnrd wants to
sell a piece of property to XYZ Manufacturing and XYZ
needs a bank loan to go build up a building or a new
building or buy equipment, he goes to the bank and the
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- W~ll gee I don't know. I got this ~roperty that doesn't
2 belong to me yet that I might get some day. The bank's
3 not going to look too favorably upon that. So that was
4 one (1) of the reasons why that change in the law was
5 made to allow companies to actually gain title and the~
6 they could use the title as collateral to obtain loans
7 and to facilitate a - a better redevelopment and re-use
8 of property that was formerly in a military installation.
9
10 MS. JAE BREITWEISER:
11 ! see this as a problem, very large
12 problem for our community with this being done, like
13 piece of forty (40) acres here and forty (40) acres over
14 here and our county doesn't actually own that.
15
16 MR. PAUL CLOUD:
17 Oh the county wi 11 nevet· "own" it.
18
19 MS. JAE BREITWEISER:
20 ! kn0w. B•1t they don't ev~n have
21 jurisdiction.
22
23 KR. PAUL CLOUD:
24 No ma'am that's not true.
25
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MS. JAE BREITWEJSER:
For zoning.
MR. PAUL CLOUD:
That's not true. Back in 1995 the
gov~rnor signed wh&t's call~d a lett~r of recision.
MS. J1-.E BREI '!'WEISER.:
That's good.
MR. PJI.UL CLOUD:
And the state, including the
counties, now have legal jurisdiction on JPG. It.'s what
called concurrent jurisdiction. The county sheriffs can
patrol, come in, issue tickets. You know arrest people
where as before that time it was what they call exclusive
federal jurisdiction. And they could not come on th~
property and arrest someone or give them a ticket or
bas~cally do anythjng else. So there is a legal
authority now p~~sent for the coDnties and the state on
JPG. It's called concurrent jurisdiction.
MR. DON BARNES:
Paul does that include zoning? Since
they don't own the property. thP individt1al ~oesn't own
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the property, could he dr> scmethin.g that would vid=>t.
the normal zoning laws p~ior to the transfer and the
county would not have any jurisdiction on it?
MS. JAE BREITWEISER:
There seems to be a big hole here.
MR . DON BARNES:
Do we have power to do that?
MR. PAUL CLOUD:
Mike?
MR. MIKE EARLY:
I think you would have to ~efer
comment on that to the Jefferson County Commissioners.
MR. PAUL CLOUD:
Yeah.
MR. MIKE EA..~LY:
But at the meeting that we had with
them at the court house and the EP~ was present at that
meeting. r forget when that was, but one (l) of the sid~
issues that WE:' :;~ddressed ·.atb cOllnty commlssj.on<H.s <'.nd "'t
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that time at th~t same meeting they ;ndjcated that tne
county is working on a revi~ion to the comprehensive
zoning plan and the commissioners indicated that they
were considering JPG property in that. So if you have a
question about that zoning I would - I would suryg~st to
you that you address that to the county commissioners so
that they can properly consider it in the county zon1ng
plan which is currently being updated.
MR. PAUL CLOUD:
Thank you Mike.
MS. CAROL WITT-SMITH:
Paul could we just make the
suggestion that the county be invited to RAE that maybe
you could see about maybe on the next agenda looking into
maybe somebody from th~ Louisville Corps office, real
estate office and the county officers.
MR. Pl\UL Cl,OUD:
The county. That's a very good idea.
MS. Cl\ROL WITT-SMITH:
And make a presentation of how this
works with ?on1ng wjth t};8 l~ase sgre~~entF and the
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subleases. How that prac@SS ~orks. Because it ~eems
like the public is getting the same sets of problems that
we had to deal with upon receiving the property, how it
goes through the real estate division.
HR. PAUL CLOUD:
I see Richard shaking his head yes.
Yes sir? As co-chair I think we will see that on the
next meeting's agenda. Yes sir?
MR. TIM MOORE:
Paul you said previously that the
Army is committed to four (4) feet deep.
MR. PAUL CLOUD:
That's for UXO in the cantonment area
yes s~r.
MR. TIM MOORE:
Okay. But you're talkinq about
residential uses and things that wouldn't nccur to that?
MR. PAUL CLOUD:
No that's not true. When I say
res.ideni:~al that w~uld be f.or th~ c,1-rr~nt housP.os tb;e.t a:r~
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in the housing loop. That WO\tld not be for new house~ in
an area that had been identified as having potential UXO.
If you want - if Mr. Ford at some later date wants tr.
build a house in one (1) of those areas and wants to dig
something that's going to go belo~ that, the Cllrrent
position of the Army is th?t he Wlll have to fund a UXO
clearance operat1on below the fout (4\ foot level. Jf he
wants to build a house 1n an area that does not have
potential UXO then there ar~ no restrictions. He cah dig
down as deep as he wants.
MR. TIM MOORE:
So essentially you are not going to
give anybody clear deed to it? The Army is still going
to have that four (4) foot deep
MR. PAUL CLOUD:
That's correct.
MR. TY.M MOORE~
The Army is still going to have --
MR. PAUL CLOUD:
That's correct. That is what the
Army committed to. That was many, many years ago.
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MR. TIM MOORE:
2 The Army is going to have control?
3
4 MR. PAUL CLOUD:
5 They will have --
6
7 MR. TIM MOORE:
8 It will not be a clear deed?
9
10 MR. PAUL CLOUD:
11 It's not that they will have control.
12 There will be a deed restriction. You have a house.
13 There are certain restrictions on that house. You cannot
a ' 14 go on your property and do anything anywhere on that
15 property for~ver. I'm sure there are either mineral
16 rights reserved or something else such that you know you
17 can't do something that might negatively impact the value
18 of your neighbors property or someplace else. So no one
19 really has unlimited use of their property. This is -
20 you know it's a deed re~trict1on. Tha~'s a deed
21 restriction. This would similarly be a de~d restriction.
22
23 M~. TIM MOORE:
24 If he d1gs a basement on that
25 property that of ~curse is his opt1oo. It says he cal,not
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build a house n: }Je cap'l
MR. PAUL CLOUD:
Well again if it's in an area where
there's no potential UXO there is no need to stop him
because there's no restriction. If he - if he wants to
go build it he's going to have to get a building perwjt.
A building permit --
.MR. TIM MOORE:
Does th~ Army clear this?
MR. PAUL CLOUD:
The examiner will look at th~
restrictions on the property and say it you want to hui.ld
something here it's going to require an excavation down
below tour (4) feet, there's a restrict1on in your dePd
that says you can't do that. You have to fix that before
you can dig your hole.
MR. TIM MOORE:
Is there any area of that cantonment
area other than the buildings that are currently there,
i~ there any area of that cantonment area that you people
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MR. PAUL CLOUD:
Not at this present time.
MR. JIM QUINT:
Paul?
MR. PAUL CLOUD:
Yes sir?
MR. JIM QUINT:
When you said that the U. S. Fish
and Wildlife was going to be in the management of the
natural habitat of the north area will they be merely
accepting the responsibilities of the cultural resources
up there too-:>
M.R • PAU.L CLOUD:
No .sir.
MR. JIM QO!NT:
Who w1ll maintain that property?
MR. PAUL CLOUD:
~hat's th• Army's responsibility.
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MR. JIM QUIN'I':
They will.
MR. PAUL CLOUD:
Yes sir. They may enter into anoth~r
agreement with someone else whc addressed that, but
currently that's net the Army's responsibility,
MR. DAVID NOVAK:
Because thP.re are some national
register buildings up there.
MR. PAUL CLOUD:
Yes sir. That's the Army's - those
are the Army's responsibilities. Laura do you have a
question?
MS. t.AURA HODGES:
Yeah I do. You sajd earlier in the
meeting that D~an Fcrd 1~ ~lready subleasing part nf ~h~
property?
MR. PAUL CLOUD:
He has subleased some of the
buildings. Specific case ls building lOS to J&R Sta~ping
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Company. Another one is Ball Corporation who has woodeD
pallets in there. If you would like a detailed list Ken
can provide that to you. Mr. Ford periodically sends the
Army, through the Corps of Engineers, lists of potential
re-uses and then ~e evaluate them to make sure that
there's not a restriction either due to UXO or to
environmental or any other restriction and provide that
information back to Mr. Ford through the Corps of
Engineers and then he can act on that.
MS. LAURA HODGES:
I would like to have that yes. Thank
you.
MR. PAUL CLOUD:
Any other - Cathy?
MS. CATHY HALE:
Yeah. If this takes five (5) years,
seven (7) years, what~ver to transfer this property to
him and he's doing all this subleasing, is there any
property taxes that may go back on - if it's a~tually not
transferred to him?
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MP , PAUL CI.OUD:
I don't think r can answer thar. I
would probably have to refer you to the Corps of
Engineers real estate. I really don't know. I know what
I think but what I think is 1rrelevant. ! don't know.
MS. CATHY HALE:
The forty (40) acres is that clean
now? Or is that --
MR. PAUL CLOUD:
Yes. We believe it's clean. There
are some asbestos issues. There are some lead based
paint. But governor to the same historical criteria that
your building is but other than that we don't believe
there's anything. That will be I think adequately
documented in the FOST when it comes out later this montb
or next month. And it will discuss the area.
MR. RICHARD HILL:
It's probably clear of UXO also?
MR. PAUL CLOUD:
Yes. We don't believe it's in a
potential UXO area. ~.ny other qnesti ons?
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MR. DAVID NOVAK:
2 Paul could 1 Just clarify s~mething
3 real quick for the folks here? I'm Dave Novak. I'm with
4 public affairs ~ith !P~ out of Chicago. And part of the
5 process which Corrine was explaini~g on community
6 involvement, at a normal Superfund site that we've got a
7 lot of clean up going on it's a very aggressive program.
8 F.:ere, because you don't have that type of threat and
9 given the community, it's not as aggressive. However,
10 the same rules apply. Keep the community informed. And
11 over the last couple of months that we've been talking or
12 the State has been involved, communities around here and
13 several of the people here already brought up concerns • 14 .
saying we don't know what's happening, this whole
15 community involvement portion of it is to get out there
16 like Corrine s~ys talk to the community, talk to the
17 residents anrl everybody around. f'T1d this includes th.,.
18 entire fifty-five thousand (55,000) acres not just the
19 southern part, find out what your con~erns are so that
20 over the course of the next several years or whatever
21 amount it takes, your questions are going to be answer~d.
22 And that's the whole idea of re-assessing community
23 involvement. It's spearheaded of course by the Army with
24 other concerns. And again our concern as EPA of the
25 State is not as it 1s structured under the Superfund.
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But we ar~ concerned and we want to get the information
cut and that's coming up tonjght that there is some stuff
out there you don't quite understand. Jl.nd that's the
idea of the emphasis on community involvement. So you
can have better lines of comreunication back and forth.
So you know what's happening out there.
HR. P~UL CLOUD:
Laura?
MS. LAURA HODGES:
I just want to make very sure I
understand. Have we been named a Superfund site?
MR. PAUL CLOUD:
No. No we have not.
MR. DAVID NOVAK:
No we're just here ~s an involvement.
Like I say Karen is a Superfund video project manager. I
am over all community involvement. When we get into a
Superfund site I really get heavily involved. Here I'm
not involved only as interested because the community is
involved in this site also. But no, it's not a Superfund
site. Don't get scared over that.
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M.R . PAUL Cf,OUD:
Let me try to explain it a different
way Laura. There are basically two (2) regulations you -
there are two (2) basic regulations you can apply to use
for clean up at a facility whether it's a military
facility, it's a gas station. it's a manufacturing plant
or anything else. One (1) is what Carol is an expert in
is RCRA hazardous waste. That's for things that you're
basically doing now. generating now, dispos1ng of and
retrieving now. The other one is what Karen is an expert
in and that's called CERCI.A. That's what .John is an
expert in. That's for basically things that you did in
the past maybe five (5), ten (10), fifteen (15), twenty
(20), fifty (SO) years ago that there weren't regulations
for at that time. Now if in fact an assessment is done
on a facility, and there was one (1) done of JPG, it's
basically called a hazardous range scoring - HRS. If you
reach a certain numerical number then you are recommend~d
or suggested for inclusion or you will be placed on the
NVL. As far as I know JPG has not been recommended to be
placed on that list. In that case because we are not OD
the Superfund list in theory there's no real mechanism
for the Army to go use for the clean up of the Proving
Ground. Therefore we're doing what's called a voluntary
CERCLA operation. It's basically CERCLA in all r~spects
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the Superfund list. Sn that is a difference. The ott.e~
difference is because ~e're not on the Superfund, inst~ad
of EPA being "lead regulator", then that lead regulatory
status falls to the state. But t~ey have a significant
contributor in EPA because the EPA has significant
technical resources that the state, just not Ind1ana, but
all states don't have so they are very intimately
involved in the process. So maybe that explains jt a
little bit better.
MR. DAVID NOVAK:
The resourc~s of all of ~hem are
being used towards this end.
MR. PAUL CLOUD:
And because we're a BRAe facility,
base closure facility, we have formed and it has been
formed for several years now, it's called BRAC clean up
team, BCT. And that comprises Karen from the EPA, .John
from the State and myself from the Army. And we
representing our agencies will after all the information.
the eco risk assessment, human health risk assessment,
the remedial investigation, the feasibility study that
analyzes the vario~s methods that we might use to go
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clean up the ?rovin~ Grottnd, we will rnake the decision on
which methods to go use and at ~hat levels ar~ ne~ess~ry
to go clean 11p part of what we factored into that would
be the level of re-11s~ th3t will be formed. So it's not_
a very simple you know yes bl~ck and white, no type of
issue. But it incorporates a whole numbe~ cf things.
But no we are not on the Superfund list. Yes sir?
MR. TIM MOORE:
How can we call JPG officially closed
when you still have an active range on the property?
MR. PAUL CLOUD:
The facility as an active Army
facility is in fact legally officially closed.
MR. TIM MOORE:
Then how can they legally officially
keep title --
MR. PAUL CLOUD:
That is the Air National Guard. They
have a license or permit to go continue that operation as
had been endorsed by the Secretary of the Army when he
was here in October. And it is his intent that the Army
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continue to allow that op~!~tion.
MR. TIM MOORE:
I don't see how we can cal\ it
closed.
MR. PAUL CLOUD:
From an Army prospective it was
mandated by law to be closed as an Army facility and it
is so closed. Yes sir?
MR. CLYDE CAMPBELL:
You said the Department of Interior
referred to it as a National Wildlife Refuge? That's
what they were interested in?
MR. PAUL CLOUD:
They were i~terest in that. They
made appllcation --
MR. CLYDE CAMPBELL:
How about the State of Indiana?
MR. PAUL CLOUD:
They did not make an application or
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request for any of the n~op~rty when they had tha~
opportunity.
MR. CLYDE CAMPBELL:
All right. And then going back you
said something about the Wildlife was going to take their
flfty-six thousand (56,000) acres?
MR. PAllL CLOUD:
Fifty-one (51,000).
MR. CLYDE CAMPBELL:
Fifty-one (51,000). Okay.
MR. PAUL CLOUD:
North of the firing line.
MR. CLYDE CAMPBELL:
All right.
HR. PAUL CLOUD:
It's basically the Army for the next
three (3) years will provide funding for them so that
they can get the funding into their budget cycle.
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MR. CLYDF CAMPBELL:
Okay.
MR. PAUL Ci.OUD:
Then three (3) years from now - so
three (3) years from now the Army won't be paying the"'·
They will h3ve it in their budget and they will continue
to do the same function.
MR. CLYDE CAMPBELL:
To do what?
MR. PAUL CLOUD:
To manage the natural refuge, the
birds, the bunnies, the deer, the endangered species
which is the Indiana bat which is up north. Those types
of functions. None of the cultural natural resourc~s.
That is their charter.
MR. CLYDE CAMPBELL:
As far as public use?
MR. PAUL CLOUD:
No. We are not talking public use no
sir.
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MR. CLYDE CAMPBELL:
Okay. So myself in com1ng to this
meeting and setting here and interested in public use of
~he fifty-one thousand (51,000) acres--
MR. PAUL CLOUD:
At this present time there are no
pians for public use north of the firing line. That is
not to say that at a future date that might change. But
currently that is an accurate statement.
MR. CLYDE CAMPBELL:
Great. I'll keep on coming.
MS. CAROL WITT-SMITH:
And could you just clarify one (l' of
the reas0ns why they backed out on the refuge deBl w~5
that the EPA sent some major comments about the portion
of the refuge that had to be open to the general public
and the question of will they do clean up or not and what
level on that portion of that can go back to open to the
public? Once it was discussed that all the permitting
and requirements that would have to be added into the
requirement for Fish and Wildlife they kind of backed out
of the deal because of a lot of these issues of our
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agency not wanting tn seA north of the firing line opAn
to general public type of action here. It's because of
the unresolved issues of how to deal with UXO. So that
was kind of what was leading that so in this respect it
was MOO. It's a good thing this Fish and Wildlife
primarily wanted the concern of saving a habitat species
north of the firing lin~ and they could b~ a land manager
without the impact by the regulatory agencies to say
you're an owner or an operator.
MR. PAUL CLOUD:
Theylre basically going to be like a
contractor.
MS. CAROL WITT-SMITH:
It's much 1nore beneficial in that
respect.
MR. PAUL CLOUD:
Any other questions?
MR. TIM MOORE:
What's EPA's plans and involvement
from now on? I know we went through these assessments
and everything. Is EPA going to basically take over all
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the ecological - is the ~rmy going to ba~k completely out
of the EPA and Just make sure that all regulations of t~e
EPA be followed north of the firing line?
MR. PAUL CLOUD:
I will let EP~ respond to that. I
don't want to intrude on EPA. I don't want to speak for
the EPA.
KS. CAROL WIT'!'- SMITH:
I mean in the sense that we will
guarantee compliance of regulations. I think in the
contents north of the firing line right now the biggest
regulatory aspect is the open detonation range is going
for closure. So we're working with the Army on getting a
formal closure of the open detonation range which is
basically centralized north of the firing line. As part
of that we also look at security because the perimeter
fence is the security for that detonation range. So
we're working with the Army on making sure that security
is maintained for north of the firing line. And as far
as the - the other concerns would be we've already done
what's called RCRA facility assessment for north of the
firing line and identified sp~cific units where we might
have concerns abcut waste management in the past. Those
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3ll the ranges th~t once thPy became closeri, all except
for the Air National Guard range, wh1ch is still active,
is that then they became solvent waste management units.
So there is RCRA authority in the sense of future
investigations of the area to see if they is really
anything that's hazardous or not. So it's like the next
phase of things and it's a matter of scheduling. I mean
currently the funding on the budgets are - are pushing
more south of the firing but we'r~ going to be working on
the closure activities, the security issues north of the
firing line right now. And then leaning towards, as soon
as there's settlement of this range rule, munitions rule
issue between our two (2) headquarters, once those things
settle out which should be fairly soon, then we will kind
of have a frame work of how we're going to start looking
at landfills. And there's a priorization system that
they have to go through for ranking the ranges and then
figuring out which phases will get funding to look at
ranges. So that's all kind of coming down the line and
it gives us more authority to make sure that the phases
are done. So there is progression and we are starting to
look at north of the firing line issue.
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MR. TIM MOORE:
Well I didn't see the E?A involved
o:!arli"!r.
MR.. PAUL CLOUD:
The EPA has been involved for several
years.
MS. CAROL WITT-SMITH:
We've been involved.
MR. PAUL CLOUD:
It may not have been evident as it is
now but they have been formally and officially involved
for several years.
MR. TIM MOORE:
Could you explain to me what - you
made the statement solvent waste management units?
MS. CAROL WITT-SMITH:
Yeah. Solvent management units are
basically any unit whether it's a container, a tank, a
landfill, anything that contains by storing, treating,
say you were burning something in a ground, or had any
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kind of management practice behind it of solid w?~te.
that that becomes listed in ~orrective action as a
solvent waste management units. And so every solvent
waste management unit that gets identified on the entire
base we go through the system of documenting what it i~.
what kind of waste 1o1ere handled by that. whether it was
paper "aste in a trash C.Rll or you know red J.ead in <'
container. So tl1ose get all documented and they go
through an evaluation system where you figure out has
anything been mis-managed, somebody release something,
spilled something on the ground? And then we look
through the same sort of thing of Superfund process and
evaluate the need to clean up activity. And that's done
on the RCRA side. So it's kind of like south of the
firing line what's being done through Karen and John. On
the Superfund side it's a parallel to what RCRA 1o1ould
require. So it's kind of like you do a duplicate review
and RCRA helps Superfund to make sure that there's
compliance with both laws at the same time instead of
coming back five (S) or ten {10) years down the line.
But we also work on both north and south of the firing
line.
MR. TIM MOORE:
You are just looking at existing
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dumps? You're not looking at new dumps that h~vB he~~
put in?
MS. CAROL WITT-SMITH:
We don't look at new sitings unless
it's an actual - say somebody wanted to re-use part of
the base as a brand new landfill. Well that would have
to go through the whole sit1ng processes that the state
has in place for the solvent waste program seeing if it's
a prop~r site. It has to go through all that. You can't
just create something new.
MR. PAUL CLOUD:
Yes ma'am?
MS. JAE BREITWEISER:
I just have one (1) more question.
You probably answered this and I haven't caught it.
Because there are several of us here for that reason.
One {1) who is going to be responsible for the up keep
and repair and maintenance of Old Timbers and the school
house that is out there and are historical?
MR. PAUL CLOUD:
That's an easy answer. That's the
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ArTny.
MS. JAE BREITWEISER:
The Army w1ll maintain that?
MR. PAUL CLOUD:
The Army is responsible. We own the
property until such time as we do not own th~ property.
We are responsible for the up keep and the maintenance of
the entire facility in compliance with all laws whether
it's cultural, historical, natural resources, it's an
environmental law or it's anything else. We are
responsible.
MS. JAE BREITWEISER:
We wanted that clarified.
MR. PAUL CLOUD:
Yes ma'am. Any other questions? I
would say we probably did our open discussion then. I
will kind of flip the closing remarks around since I'm
already on my feet and just make the announcement that
our next planned RAB meeting is for Tuesday, March 4th
here. I have no further closing remarks other than to
again to encourage you to sign our attendance sheet, take
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one (11 oE my business cards.
number that you can call me on. And if you have someone
you would like to give a card to, Ken has additional
cards that he can give out and we will go from there.
Richard?
MR. RICHARD HILL:
I thought we had a lot of good
questions tonight and it's real obvious that we're going
to have a lot more good questions. Or a lot more
questions. I don't know how good they will be but we
will have a lot more. I like to see that kind of
participation because that has been a little bit lacking.
I mean if you don't come to every meeting you miss out on
things as far as to keep caught up because ther~ is so
much going on. So I encourage people unt1l such time
that we get this Community Involvement Program going just
perfectly, you just keep coming to the meetings. Okay~
Yes?
MS. DOTTIE REINDOLLAR:
Because all of us can't always come
to all of the meetings could the Army and the
environmental get more media releases out so that we can
keep up without having to go the Hanover College?
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MR. RICHARD HILI,:
2 I th1nk that's one fl) of the goals
3 or should be yes. That's a good recommendation.
4
5 MS. LAURA HODGES:
6 I h~v~ a comment too Richard. You
7
8 say Ha.rch 4th?
9
10 MR. RICHARD HILL:
11 I think that's correct. That's what
12 we had on the papers. Is that not a good day?
13 • 14 MS. LAURA HODGES:
15 Let me explain why that's a really
16 terrible date. Okay? If what you want is community
17 involvement if you want your city representatives and
18 your county representatives here, you are continuing to
19 put these meetings on the same night as the City Council
20 meeting when every elected official in tbe City of
21 Madison plus all the people who work for the City of
22 Madison, like the Special Projects Administrator, have
23 to be at City Hall all evening. And then secondly
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MR. RICHARD HII.L:
No one ever told us that.
MS. LAURA HODGES:
No one ever told you that? Did you
ever ask what is a good day to have these meetings?
MR. PAUL CLOUD:
They were asked and we provided
information as to when the meetings were going to be and
asked if that presented a problem or not. But we have
never gotten any feedback saying we prefer another time.
MS. LAURA HODGES:
I gave you feedback at the time you
scheduled it on election night. That was a really,
really bad night. I gave you feedback about six (6)
weeks before the meeting.
MR. PAUJ, CLOUD:
I understand that. Unfortunately
there are certain other things we have to take into
consideration.
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.MS. LAURF-. HOD~ES ·
Th~ second really bad reason 1s thHt
the county also has meetings that go on this night. The
County Plan Commission and the County Board of Zoning
Appeals meet and that involve~ Steve Lyons, who is the
president of the Co~nty Commission. He's in effect our
county administrator. He cannot be at these meetings
because he has to be in the court house on the first
Tuesday of the month.
MR. DAVID NOVAK:
What's your best time? What's your
free night during the week?
MR PAUL CLOUD:
What would you as a member of the
community recommend? Whether you're officially with th~
press or just a member of the community?
MS. LAURA NODGES:
Well another Tuesday besides this.
At least go to the second Tuesday. Or the fourth
Tuesday that would work. Or if it was a Wednesday. Or
the second Monday.
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MR. DAVID NOV.l\K:
What night is a good night? Is th1~
not a good night?
MS. LAURA HODGES:
No a lot of people couldn't b~ here
on Wednesday night because of church.
MR. DAVID NOVAK:
Yeah that's right. Wednesday's are
not a good night.
MS. LAURA HODGES:
Thursday nights are bad too.
MR. DAVID NOVAK:
Thursdays a~e bad too.
MR. PAUL CLOUD:
Second Tuesday. r appreciate your
comment and that is relevant. I may retract my pr~viou~
statement. The community co-chair, Richard and I, will.
discuss the issue, get input from not only the regulators
but the community and we will then announce when the next
RAE meet1ng will be. It may not be March the 4th. Tt
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may be a different date. Thank you.
That's all we hav~. I appreciate your coming. Again
sign our attendance sheet. Thank you.
* * * * '* CONCLUSION OF HEARING
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c E R T I F I c Pt T E
STATE OF INDI.l\NA ) ) SS:
COUNTY OF .JEFFERSON )
I I Sharon Shields, do hereby certify that I am
a Notary Public in and for the County of Jefferson, Slat•
of Indiana, duly authorized and qualified to administer
oaths; That the foregoing public hearing was taken by me
in shorthand and on a tape recorder on January 7, 1997 in
the offices of the Salvation Army Headquarters, 331 East
Main Streftt. Madison, IN; That this public hearing was
taken on behalf of the Jefferson Prov1ng Ground
Restoration Advisory Boarfi pursuant to agreement for
taking at this time and place; That the testimony of the
witnesses was reduced to typewriting by me and contains a
complete and accurate transcript of the said testimony.
I further certify that pursuant to stipulation
by and between the respective parties. this testimony ha~
been transcribed and submitted to the Jefferson Proving
Ground Restoration Advisory Board.
WITNESS my hand and notarial seal this 13th day
of January, 1997.
My Commission Exp1res: July 2, 1999
__ ____x[~ y£e£L) Sha~on Shields, Notary Public
Jefferson County, State of Indiana
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