east fork valley mrs proposed plan

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FORMER CAMP HALE COLORADO PROPOSED PLAN FOR MILITARY MUNITIONS RESPONSE PROGRAM EAST FORK VALLEY MUNITIONS RESPONSE SITE INTRODUCTION This Proposed Plan identifies the United States Army Corps of Engineers (USACE) preferred remedial (cleanup) alternative for addressing hazards associated with military munitions at the East Fork Valley (EFV) Munitions Response Site (MRS), located at the former Camp Hale, Colorado. The USACE is conducting this work under the Military Munitions Response Program (MMRP). The U.S. Department of Defense (DoD) established the MMRP to address Unexploded Ordnance (UXO), Discarded Military Munitions (DMM), and Munitions Constituents (MC) at defense sites, which are categorized as Munitions Response Areas and MRSs, including on Formerly Used Defense Sites (FUDS) under the Defense Environmental Restoration Program (DERP). The DoD operates as the lead agency for FUDS under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The USACE Omaha District is the executing agency for the MMRP at Camp Hale. The U.S. Forest Service (USFS) owns and manages the majority of the land within the Camp Hale FUDS boundary. The U.S. Environmental Protection Agency (USEPA) and Colorado Department of Health and Environment (CDPHE) are regulatory stakeholders for Camp Hale FUDS. The purpose of this Proposed Plan is to facilitate public involvement in the remedy selection process by providing background information about Camp Hale and the EFV MRS, presenting the rationale for selecting the preferred alternative, and summarizing the other alternatives considered. This Proposed Plan is being issued as part of the public participation responsibilities under Section 300.430(f)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan and Section 117(a) of CERCLA. Camp Hale is not on the CERCLA National Priorities List (NPL); however, under the FUDS program, MMRP sites follow the CERCLA process. After the close of the public comment period, the U.S. Department of Army will issue a Decision Document (DD) announcing its selection of the final remedy for the EFV MRS. This Proposed Plan summarizes information that is presented in detail in the Remedial Investigation (RI)/Feasibility Study (FS) and other documents in the Camp Hale Administrative Record File. The Administrative Record is a compilation of the information that was considered in formulating the proposal presented in this Proposed Plan, and presents a comprehensive description of the site investigation and proposed remedial alternatives. Dates to Remember: A) Public Comment Period July 24, 2015 to August 24, 2015 The USACE will accept written comments on the Proposed Plan during a 30-day public comment period. Comments can be submitted via email to: Adam Little, Project Manager [email protected] Or by US Postal Service to: Adam Little, Project Manager Omaha District CENWO-PM-H 1616 Capitol Avenue Omaha, Nebraska 68102 B) Public Meeting A public meeting to explain the Proposed Plan will be provided upon request. For more information, see the Administrative Record File, located at: Lake County Public Library Reference Section 1115 Harrison Avenue Leadville, CO 80461 or The Camp Hale website at: http://www.camphale.org July 2015 1

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Page 1: East Fork Valley MRS Proposed Plan

FORMER CAMP HALE COLORADO PROPOSED PLAN FOR

MILITARY MUNITIONS RESPONSE PROGRAM EAST FORK VALLEY MUNITIONS RESPONSE SITE

INTRODUCTION This Proposed Plan identifies the United States Army Corps of Engineers (USACE) preferred remedial (cleanup) alternative for addressing hazards associated with military munitions at the East Fork Valley (EFV) Munitions Response Site (MRS), located at the former Camp Hale, Colorado.

The USACE is conducting this work under the Military Munitions Response Program (MMRP). The U.S. Department of Defense (DoD) established the MMRP to address Unexploded Ordnance (UXO), Discarded Military Munitions (DMM), and Munitions Constituents (MC) at defense sites, which are categorized as Munitions Response Areas and MRSs, including on Formerly Used Defense Sites (FUDS) under the Defense Environmental Restoration Program (DERP). The DoD operates as the lead agency for FUDS under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

The USACE Omaha District is the executing agency for the MMRP at Camp Hale. The U.S. Forest Service (USFS) owns and manages the majority of the land within the Camp Hale FUDS boundary. The U.S. Environmental Protection Agency (USEPA) and Colorado Department of Health and Environment (CDPHE) are regulatory stakeholders for Camp Hale FUDS.

The purpose of this Proposed Plan is to facilitate public involvement in the remedy selection process by providing background information about Camp Hale and the EFV MRS, presenting the rationale for selecting the preferred alternative, and summarizing the other alternatives considered. This Proposed Plan is being issued as part of the public participation responsibilities under Section 300.430(f)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan and Section 117(a) of

CERCLA. Camp Hale is not on the CERCLA National Priorities List (NPL); however, under the FUDS program, MMRP sites follow the CERCLA process. After the close of the public comment period, the U.S. Department of Army will issue a Decision Document (DD) announcing its selection of the final remedy for the EFV MRS.

This Proposed Plan summarizes information that is presented in detail in the Remedial Investigation (RI)/Feasibility Study (FS) and other documents in the Camp Hale Administrative Record File. The Administrative Record is a compilation of the information that was considered in formulating the proposal presented in this Proposed Plan, and presents a comprehensive description of the site investigation and proposed remedial alternatives.

Dates to Remember:

A) Public Comment Period July 24, 2015 to August 24, 2015 The USACE will accept written comments on the Proposed Plan during a 30-day public comment period. Comments can be submitted via email to:

Adam Little, Project Manager [email protected]

Or by US Postal Service to: Adam Little, Project Manager Omaha District CENWO-PM-H 1616 Capitol Avenue Omaha, Nebraska 68102

B) Public Meeting A public meeting to explain the Proposed Plan will be provided upon request.

For more information, see the Administrative Record File, located at:

Lake County Public Library Reference Section 1115 Harrison Avenue Leadville, CO 80461 or The Camp Hale website at: http://www.camphale.org

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Figure 1 – Location of Camp Hale and East Fork Valley MRS

SITE BACKGROUND Camp Hale is located approximately 70 miles west of Denver, Colorado. Camp Hale spans Eagle, Summit, Pitkin, and Lake Counties between the towns of Red Cliff and Leadville. The location of the East Fork Valley MRS at Camp Hale is shown on Figure 1. In the FUDS Management Information System (FUDSMIS) Camp Hale is FUDS Property Number B08CO0014 and the EFV MRS is Project No. 05. Camp Hale was established in 1942 to provide winter and mountain warfare training during World War II. Camp Hale was acquired by purchase from private owners and by use permits from the USFS. Military use of Camp Hale included the 10th Mountain Division, the 38th Regimental Combat Team, 99th Infantry Battalion, and soldiers from Fort Carson conducting mountain and winter warfare training exercises from 1942 to 1965. Throughout this time, the Army tested a variety of weapons and equipment at Camp Hale.

The East Fork Valley MRS is a 611-acre area that was the primary training area used by the Army and CIA for training with a variety of munitions including small arms, bulk explosives, hand grenades, rifle grenades, anti-tank practice landmines, rockets, mortars, and projectiles.

SITE CHARACTERISTICS The RI performed at the East Fork Valley MRS was finalized in May 2015. The RI determined the nature and extent of contamination, and identified the potential for Munitions and Explosives of Concern (MEC) and Munitions Debris (MD) to be present on the ground surface or below ground. MEC is a term for categories of military munitions that may pose explosives safety risks. MD is a term to describe remnants of munitions that do not pose explosives safety risks. The RI found no evidence of MC at levels that present a risk to human health or the environment. MC are chemical constituents originating from emission, degradation, or breakdown of MEC or MD.

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The EFV MRS is described in the 2015 FS. The FS provides the decision makers with an assessment of the remedial alternatives, including their relative strengths and weaknesses, and trade-offs in selecting one alternative over another. The remedial action technologies and process options that are considered are defined as remedial action alternatives.

The EFV MRS occupies the majority of the East Fork Valley extending approximately 2.8 miles eastwards from the mouth of the valley as shown

on Figure 2. The valley is bounded by an abrupt topographical change to steep slopes to both the north and south. In the western part of the MRS the valley is relatively open and flat, but towards the east the ground surface becomes more uneven and rocky with more trees.

Historical range clearances were conducted within Camp Hale in 1946 and 1965. In 2001 a Time Critical Removal Action (TCRA) was conducted within portions of the EFV MRS along the Colorado Trail; and in 2003, a TCRA consisting of 100 percent surface clearance was performed within most of MRS. Within the 2003 TCRA area, there are some marshy areas that could not be accessed for clearance activities.

Subsurface MEC was not addressed during the TCRAs, thus subsurface MEC may be present throughout the MRS. Three subsurface MEC items were found during a technology demonstration project in 2014 in the MRS: two 81millimeter (mm) mortars (M56), and one 60mm illumination round.

For convenience of developing and presenting remedial alternatives in the FS the EFV MRS is divided into three sub areas:

• Area A – this includes the bulk of East Fork Valley. Most of Area A was included in the TCRA in 2003 consisting of 100 percent surface clearance.

• Area B – this includes a target area at the eastern end of East Fork Valley. This area generally has a higher density of MEC and MD than Area A based on previous investigations. Part of Area B was included in the 2003 TCRA.

• Area C – this includes the western end of East Fork Valley. This area generally has a lower density of MEC and MD than Area A based on previous investigations. Area C was not included in the 2003 TCRA.

For the purpose of this Proposed Plan, the three areas are discussed as the EFV MRS. The locations of these Areas are shown on Figure 2.

What are Munitions and Explosives of Concern (MEC)? – Munitions and Explosives of Concern, or MEC, is a term that specifies categories of military munitions that may pose explosives safety risks. MEC may include unexploded ordnance (UXO) (generally munitions that were fired or prepared for firing, which remain unexploded due to malfunction); discarded military munitions (generally munitions that have been abandoned without proper disposal); or high concentrations of munitions constituents in high enough concentrations to pose an explosive hazard, such as trinitrotoluene (TNT). MEC found at EFV MRS include, practice landmines, rockets, grenades, and mortars

What is Munitions Debris (MD)? – Munitions Debris is a term used to describe the remnants of munitions remaining after munitions use, demilitarization, or disposal. MD that is properly identified by qualified personnel is not hazardous. MD found include practice landmines, projectiles, mortars, rockets, flares, and grenades.

What are Munitions Constituents (MC)? – Munitions constituents, or MC, is a term used to describe a chemical compound or element originating from unexploded ordnance, discarded military munition, or other military munitions. These chemical compounds may be found in the environment such as in soil, surface water, or groundwater. MC were determined not to pose a human health or ecological risk at EFV MRS.

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Figure 2 – Location of the East Fork Valley Areas

These three areas relate to the proposed MRSs in the RI as follows:

RI FS Area (acres)

EFV A MRS EFV MRS Area A 457 EFV B MRS EFV MRS Area B 52 EVS D MRS EFV MRS Area C 102 Total 611

The Camp Hale East Fork Group Campground is located within EFV MRS and the Camp Hale Memorial Campground is nearby. The Colorado Trail passes through the MRS and there is a parking area where the trail crosses National Forest System (NFS) Road 714. There are no

sensitive receptors such as schools or churches within a 4-mile radius. An underground natural gas pipeline and an overhead power line owned by Xcel Energy run through East Fork Valley. The USFS is currently in the planning stages of a streambed restoration project within the East Fork Valley. The project would restore the East Fork of the Eagle River to a more natural state by re-routing its flow into a meandering path through the valley. The project would involve intrusive work within the EFV MRS. Most of the EFV MRS is owned by USFS. A privately owned land parcel extends into the eastern portion of the MRS. Land use within EFV MRS is illustrated on Figure 3.

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Figure 3 – EFV MRS with Site Features

SCOPE AND ROLE OF RESPONSE ACTION This Proposed Plan addresses the EFV MRS that has been defined to include all areas within the East Fork Valley portion of Camp Hale. The action selected will be the final action for the MRS. The overall cleanup strategy is to take appropriate action to remedy hazards from MEC to protect human health and the environment when there is an unacceptable risk. Actions are selected after considering remedial alternatives and applying cost-effective solutions.

SUMMARY OF SITE RISKS The Army assessed risk to determine current and future effects on human health and the environment from MEC and MC.

The area is located within the White River National Forest (WRNF). The primary activities at EFV MRS consist of recreational snowshoeing,

cross-country skiing, hiking, camping, fishing, biking, horseback riding, and four wheeling. Sheep grazing also occurs within the MRS. Concessionaires are allowed to conduct recreational tour groups through the MRS, although they are restricted to trails and roadways.

Ecological resources potentially including threatened and endangered species are present in the area. Federally-listed threatened or endangered species that occur within Eagle County, Colorado, include the Uncompahgre fritillary butterfly, Mexican spotted owl, greenback cutthroat trout, Ute ladies’ tresses, Canada lynx, North American wolverine, yellow-billed cuckoo, and greater sage-grouse. While threatened and/or endangered species are in the region, these wildlife species have large home ranges and would not be expected to be adversely impacted by the MRS.

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MEC Hazard Assessment A MEC Hazard Assessment was performed to assess the baseline explosives hazard based on the RI results.

In 2001 and 2003, TCRAs were performed to remove MEC hazards on the ground surface. However, some areas were excluded due to inaccessibility. Also, there is the potential for buried items to be brought to the surface by processes such as frost heave or erosion. The potential for MEC to remain on the ground surface and to be accessible to receptors is low. The subsurface investigation during the RI indicates the presence of MD at depths up to 24 inches below ground surface. Subsurface MEC has been found at three locations in the demonstration project conducted in 2014. Because no complete subsurface clearance has been performed, it is assumed that subsurface MEC may be found throughout the entire MRS.

Munitions items with the potential to be present within this MRS include small arms, bulk explosives, hand grenades (practice, smoke, and fragmentation), rifle grenades (practice, smoke, and high explosive anti-tank [HEAT]), anti-tank landmines (practice), rockets (2.36-inch and 3.5-inch – practice, smoke, and HEAT), mortars (60mm and 81mm – practice, illumination, and high explosive [HE]), and projectiles (37mm, 40mm, 57mm, 75mm, 76mm, 90mm, and 106mm – HE and HEAT).

There are no physical access barriers in place in the MRS. Campgrounds, trails, and roads are present within the MRS, and a small parcel is privately owned. There is the potential for receptors to access MEC in the surface and subsurface throughout the MRS. The EFV MRS is considered to present a moderate potential explosive hazard especially for intrusive activities.

Human Health Risk Evaluation A Human Health Risk Assessment was performed using the concentrations for MC for samples collected during the SI and the RI. The Human Health Risk Assessment compared detected MC

against USEPA Regional Screening Levels. Metals were identified as a potential risk and were further evaluated.

Exposures to these metals in surface and total soil were evaluated with respect to a range of site-specific recreational and worker scenarios based on current and potential future assumptions. The Human Health Risk Assessment concluded that based on exposure assumptions for current and future land use no further action relative to MC is recommended for EFV MRS.

Ecological Risk Evaluation An Ecological Risk Assessment was performed as part of the RI to address the potential for ecological risks from exposures to MC. Concentrations of MC were screened against USEPA screening values. There is adequate information to conclude that ecological risks are negligible and therefore there is no need for further action at EFV MRS on the basis of ecological risk.

REMEDIAL ACTION OBJECTIVE A Remedial Action Objective (RAO) is the site-specific goal or goals for protecting human health and the environment. RAOs and alternatives to address MC exposure are not developed, as there is no evidence that MC is present at levels that could pose a risk to human health or the environment. Thus, the RAO addresses MEC receptors and exposure pathways and drives the development of the munitions response alternatives.

The RI for EFV MRS has established the potential for munitions associated with range activities (rockets, mortars, and/or projectiles) to be present on the surface and in the subsurface. The RAO for the EFV MRS is to reduce the hazard to recreational users, USFS personnel, utility workers and construction personnel, such that the probability of encountering hazardous munitions is negligible and the remedial response can be considered complete. This will be achieved by: 1) Eliminate to the extent practicable the

potential hazard of encountering munitions associated with range activities (rockets,

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mortars, and/or projectiles) on the surface in areas that are reasonably accessible.

2) Reduce to the extent practicable the potential hazard of encountering munitions associated with range activities (rockets, mortars, and/or projectiles) in the subsurface to depth of detection in areas where intrusive activities are reasonably expected.

SUMMARY OF REMEDIAL ALTERNATIVES The information presented here is a summary of that provided in detail in the FS for the EFV MRS. In the FS, seven remedial alternatives were developed to address MEC hazards:

The alternatives developed include:

• Alternative 1: No Action

• Alternative 2: Land-Use Controls (LUCs)

• Alternative 3: Partial Surface Clearance and LUCs

• Alternative 4: Complete Surface Clearance and LUCs

• Alternative 5: Partial Surface Clearance, Partial Subsurface Clearance, and LUCs

• Alternative 6: Complete Surface Clearance, Partial Subsurface Clearance, and LUCs

• Alternative 7: Complete Surface Clearance and Complete Subsurface Clearance.

LUCs may consist of road and trail warning signs, MEC awareness training for USFS personnel and other workers, and public communications which will include advisories on intrusive activities. Engineering controls such as fences are not considered because the property is within the WRNF and USFS policy does not allow restricting access to public lands.

The partial clearance alternatives were developed to focus remedial actions on planned re-alignment of the stream through the valley, construction

activities associated with the pipeline, and the higher level of public access and use near roads and trails. These areas would be expected to have a greater risk of exposure to any MEC present and implementing clearances would therefore result in the greatest risk reduction. The partial clearance areas are shown on Figures 4 and 5.

Table 1 provides a brief description of the alternatives. A summary of the estimates for the total project costs for each alternative are presented in Table 2.

For any alternative that does not allow for unlimited use and unrestricted exposure, a five year review is required per the 40 CFR 300.430.

How are munitions identified? Various types of sensors are used to find MEC that may be buried beneath the subsurface. Three technologies used at Camp Hale are Mag and Dig, Digital Geophysical Mapping (DGM) and Advanced Classification.

Magnetometer surveys, often called Mag and Dig rely on the magnetic properties of most MEC to identify locations where MEC may be present. Generally the area of interest is divided into a grid. The locations of possible MEC are identified and flagged. An excavation or “dig” is then performed to identify the buried object. DGM is a process whereby sensors are used to map anomalies that may indicate the presence of MEC. The anomalies are analyzed, and then relocated using high accuracy global positional system (GPS) equipment. Each target is then excavated.

Advanced Classification are methods now being developed that provide a more detailed geophysical signal and allow experienced operators to distinguish items that may be MEC from non-hazardous metal debris.

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Figure 4 – Partial Surface Clearance, EFV MRS

Figure 5 – Partial Subsurface Clearance, EFV MRS

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Table 1 – East Fork Valley MRS Alternatives

Alternative 1-No Action Under this alternative, no controls will be put into place. This alternative will not protect human health or the environment.

Alternative 2: Land-Use Controls (LUCs) ● Road and trail warning signs ● Public communications ● MEC awareness training for USFS personnel, other workers Reduces explosive hazards by modifying behavior, thus limiting exposure to MEC. Effectiveness is achieved by providing information to site visitors about how to avoid potential hazards such as including advisories on intrusive activities. MEC exposure pathways are not eliminated. LUCs are effective in managing MEC risk exposure hazards provided they are followed by site workers and recreational users. Alternative 3: Partial Surface Clearance and LUCs ● Partial surface clearance(Colorado Trail, roadway, campground, stream realignment, utility corridor, areas not cleared during TCRA in Area B and Area C; 360 acres) ● LUCs implemented for remaining surface areas and all subsurface areas. Identifies and removes surface MEC within areas not previously cleared or in high use areas, eliminating the short-term and most long-term explosive hazards, and removing surface exposure pathways. Would not address subsurface MEC. LUCs would be implemented, as described in Alternative 2, to modify worker and visitor behavior, thus limiting MEC exposure. This alternative is effective in managing MEC risks provided LUCs are followed outside high-use areas by site workers and recreational users. Alternative 4: Complete Surface Clearance and LUCs ● Complete surface clearance except wetlands ( 589 acres) ● Subsurface MEC addressed by LUCs Identifies and removes all surface MEC, eliminating the short-term and most long-term explosive hazards, and removing surface exposure pathways. Would not address subsurface MEC. LUCs would be implemented, as described in Alternative 2, to modify worker and visitor behavior, thus limiting MEC exposure. This alternative is effective in managing MEC risks provided LUCs are followed for intrusive activities by site workers and recreational users. Alternative 5: Partial Surface Clearance, Partial Subsurface Clearance, and LUCs ● Partial surface clearance per Alternative 3 (360 acres) ● Partial subsurface clearance in high use areas including campground and stream realignment (123 acres) ● DGM, mag and dig technology ● MEC in low use areas addressed by LUCs Identifies and removes surface and subsurface MEC within the high use areas, eliminating surface and subsurface pathways and short-term and long-term explosive hazard in the cleared areas. Would not completely address surface or subsurface MEC, but LUCs, as described in Alternative 2, would modify behavior, thereby reducing MEC exposure. This alternative is effective in managing MEC risks provided LUCs are followed outside high-use areas by site workers and recreational users. Alternative 6: Complete Surface Clearance, Partial Subsurface Clearance, and LUCs ● Complete surface clearance per Alternative 4 (589 acres) ● Partial subsurface clearance per Alternative 5 (123 acres; DGM, mag and dig technology) ● LUCs implemented for the remaining subsurface areas Identifies and removes surface MEC in all areas and subsurface MEC in high use areas, eliminating surface and subsurface pathways and short-term and long-term explosive hazard in the cleared areas. Would not completely address subsurface MEC, but LUCs, as described in Alternative 2, would modify behavior, thus reducing MEC exposure. This alternative is effective in managing MEC risks provided LUCs are followed for intrusive activities outside high-use areas by site workers and recreational users. Alternative 7: Complete Surface Clearance, Complete Subsurface Clearance ● Complete surface clearance per Alternative 4 (589 acres)

● Complete subsurface clearance in accessible areas (552 acres; DGM, mag and dig technology) All surface and subsurface MEC would be removed, eliminating surface and subsurface pathways and short-term and long-term explosive hazards. Unlimited use/unlimited exposure would be achieved, if feasible to fully implement. This alternative is effective as MEC is removed except for wetlands and rugged terrain.

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Table 2 – Remedial Action Alternative Costs East Fork Valley MRS

Remedial Action Alternative Total Present Worth Cost ($)

Alternative 1 – No Action $0

Alternative 2 – Land Use Controls (LUCs) $1,043,000

Alternative 3 – Partial Surface Clearance and LUCs $5,099,000

Alternative 4 – Complete Surface Clearance and LUCs $7,534,000

Alternative 5 – Partial Surface Clearance, Partial Subsurface Clearance, and LUCs

$19,079,000

Alternative 6 – Complete Surface Clearance, Partial Subsurface Clearance, and LUCs

$21,314,000

Alternative 7 – Complete Surface Clearance, Complete Subsurface Clearance

$54,272,000

Note: Costs are provided for the whole EFV MRS. Costs in the FS are provided separately for Areas A, B, and C.

EVALUATION OF ALTERNATIVES Nine criteria are used to evaluate the different remedial alternatives individually and against each other to select a remedy. This section profiles the relative performance of each alternative against the nine criteria, noting how it compares to the other options under consideration.

The final remedy is selected based on weighing the trade-offs identified during analysis of the criteria, and any comments received after the Proposed Plan has been issued. Table 3 presents the specific components of each of the nine criteria.

For any alternative that does not allow for unlimited use and unrestricted exposure (Alternatives 2 through 6), a periodic five year review is required per the 40 CFR 300.430 to evaluate the long term effectiveness of the remedy. Maintenance and monitoring of LUCs including the website, published material, training sessions, and signage will continue as long as MEC remains on site. For costing purposes maintenance of LUCS and five year reviews are assumed to continue for 30 years.

Each alternative was evaluated against the criteria listed in Table 3 and the preferred alternative was selected. A summary of the results of the evaluation of alternatives is presented below.

EFV MRS has the potential for MEC to be present based on the documented military use of the area and MEC/MD identified during the TCRA, the RI, and other clearance activities. Areas near roads or trails, the campground, the planned realignment route of the stream, and the utility corridor are considered to have a greater potential for receptors to be exposed to MEC because those areas are more likely to be visited, or are areas where intrusive activities are planned in the future.

Table 4 provides an analysis of the evaluated alternatives at EFV MRS.

Key factors that need to be considered while comparing the alternatives include:

• MEC and MD were found in visual surveys conducted in 2009 in an area previously included in the TCRA. These items could have been obscured by vegetation in the TCRA, or they may have exposed by frost heave or erosion. As a result, previous clearances of

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TABLE 3 – CERCLA EVALUATION CRITERIA FOR REMEDIAL ALTERNATIVES

Threshold Criteria 1) Overall Protection of Human Health and

the Environment: Does the alternative protect human health and the environment from exposure to risks above acceptable levels?

2) Compliance with Applicable or Relevant and Appropriate Requirements (ARAR): Does the alternative comply with the identified ARARs?

For an alternative to be selected, it must meet the two Threshold Criteria.

Balancing Criteria 3) Long-Term Effectiveness and

Permanence: Is the alternative effective and permanent for the contamination at the site?

4) Reduction of Toxicity, Mobility, or Volume of Contaminants through Treatment: Does the alternative reduce the toxicity, mobility, and volume of the contaminants?

5) Short-Term Effectiveness: What is the risk to the community, workers, and the environment during implementation of the response action?

6) Implementability: How difficult is it to implement the alternative?

7) Cost: What are the relative costs associated with the alternative?

Modifying Criteria 8) State / Support Agency Acceptance: Do

the regulatory agencies involved accept the remedy?

9) Community Acceptance: Does the community accept the remedy as viable option?

Modifying criteria will be evaluated in the DD following agency and public comments on the Proposed Plan.

surface MEC have not provided 100 percent coverage and MEC may be present in accessible areas.

• A subsurface clearance has not been performed in the MRS except in the area of an advanced classification demonstration project conducted in 2014. Both the demonstration project and the RI have confirmed that subsurface MEC is present.

• Alternative 1, No Action, is not protective of human health and the environment and is not considered further for implementation at EFV MRS.

• Alternative 2 relies entirely on LUCs to be protective while alternatives 3, 4, 5, and 6 partially rely on LUCs. LUCs are only effective if the general public, USFS personnel, utility workers and construction personnel using the MRS follow the advisories issued. In areas frequented by the public, it is difficult to ensure any advisories will be consistently followed especially over extended periods of time. This may reduce the effectiveness of LUCs alone over the long term.

• LUCs are not effective in preventing access to potential surface MEC in high use areas because they are difficult to enforce. Therefore, a surface clearance is justified in areas typically used by the public or workers, which include the planned stream realignment, the campground, utilities corridor, and within 300 feet of roads and trails. Surface clearance is more effective to meet RAOs in these areas compared to LUCs.

• Surface clearance in high use areas previously included in the TCRA clearance activities is justified because items may have been missed in the previous surveys or may have been exposed by natural processes. LUCs are adequate to reduce risk of exposure to surface MEC in low use areas previously covered by the TCRA.

• LUCs are not effective in preventing intrusive activities in high use areas because they are difficult to enforce. Therefore, a subsurface

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clearance is justified in areas where intrusive activities could be expected, which includes the planned stream realignment, the campground, utilities corridor, and along roadways. Subsurface clearance is more effective to meet RAOs in these areas compared to LUCs.

• LUCs are adequate to reduce risk of exposure to subsurface MEC in areas with low use where no intrusive activities are planned, and/or where there is low probability of MEC being present.

• LUCs will require long-term funding by USACE and maintenance by the USFS.

• Alternative 7 is the only alternative that would result in site closure and release for unrestricted use if 100 percent of the MRS can be cleared.

Table 4 – Comparison of Alternatives, EFV MRS

EVALUATION CRITERIA

Alt 1 No

Action

Alt 2 Land Use

Controls (LUCs)

Alt 3 Partial Surface

Clear, LUCs

Alt 4 Complete Surface

Clear, LUCs

Alt 5 Partial Surface, Partial

Subsurface Clear, LUCs

Alt 6 Complete Surface, Partial

Subsurface Clear, LUCs

Alt 7 Complete Surface &

Subsurface Clear

Overall Protectiveness of Human Health and the Environment ○ ◐ ◐ ◐ ● ● ●

Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

○ ● ● ● ● ● ●

Long-Term Effectiveness and Permanence ○ ◐ ◐ ◐ ● ● ●

Reduction of Toxicity, Mobility, or Volume through Treatment ○ ○ ◐ ◐ ● ● ●

Short-Term Effectiveness ● ● ◐ ◐ ○ ○ ○ Implementability ● ● ● ◐ ◐ ◐ ○ Cost ● ◐ ◐ ◐ ○ ○ ○ State Acceptance To be determined

Community Acceptance To be determined

● Most Acceptable ◐ Moderately Acceptable ○ Least Acceptable

PREFERRED ALTERNATIVE Alternative 5, Partial Surface Clearance, Partial Subsurface Clearance, and LUCs, is the

preferred alternative for the EFV MRS. This alternative will involve:

• Surface removal will be performed along and near the Colorado Trail, roadways, the

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campground, along the proposed stream realignment, along the utility corridor, and the areas that were not cleared during the TCRA including all of Area C as shown on Figure 4. The estimated area for surface clearance is 360 acres, about 60 percent of the total MRS area.

• Subsurface removal will be performed along and near the Colorado Trail, roadways, the campground, along the proposed stream realignment, and along the utility corridor as shown on Figure 5. The estimated area for clearance is 123 acres, about 20 percent of the total MRS area.

• LUCS will include warning signs, MEC awareness training for forest and construction workers as needed, public communications including flyers and a website and advisories for any intrusive activities. Many of these LUCs are already in place. LUCs will require long-term funding by USACE and maintenance by the USFS.

• A periodic five year review is required per the 40 CFR 300.430 to evaluate the long term effectiveness of the remedy. Maintenance and monitoring of LUCs including the website, published material, training sessions, and signage will continue as long as MEC remains on site.

This alternative is selected based on the tradeoffs between the various modifying criteria including the implementation challenges, short-term effects on workers, and cost benefit. This alternative can be implemented to meet ARARs. The ARARs that are applicable to the preferred alternative are:

• Endangered Species Act, 16 U.S.C. § 1538(a)

• Migratory Bird Treaty Act, 16 U.S.C. § 703(a)

• Colorado Nongame, Endangered or Threatened Species Conservation Act, 2 C.C.R. § 406 Chapter 10, pursuant to C.R.S. §§ 33-2-101 et seq.

• Archaeological Resources Protection Act, 16 U.S.C. §§ 470ee sections (a) and (b)

• Colorado Noxious Weeds, 8 C.C.R.1206-2, Parts 3 and 4 pursuant to the Statute at § 35-5, 5-101 to 119

• Miscellaneous Units, 40 CFR Part 264.601, Subpart X.

The preferred alternative meets the RAO for exposure to surface MEC by performing 100 percent clearance in areas that were not included in the previous TCRA (except wetlands) as shown on Figure 4, plus repeating surface clearance in high use areas that were included in the TCRA. The alternative meets the RAO for exposure to subsurface MEC by performing subsurface clearance in high use areas such as the campground and in areas where intrusive activity is expected such as the proposed streambed alignment as shown on Figure 5. Alternatives that would involve complete surface and/or subsurface clearance are not selected because they would involve a small additional benefit relative to the preferred alternative with much higher cost.

CDPHE and USEPA Region 8 have reviewed the RI and the FS. It is anticipated that these agencies will support the Preferred Alternative. Federal and State concerns or comments will be addressed during the DD stage.

Based on information currently available, the USACE believes the Preferred Alternative provides the best remedial alternative with respect to the evaluation criteria. The USACE expects the Preferred Remedial Alternative to satisfy the following statutory requirements of CERCLA Section 121(b): 1) be protective of human health and the environment; 2) comply with ARARs; 3) be cost effective, and 4) utilize permanent solutions and alternative treatment technologies to the maximum extent practicable. The action selected will be the final remedy for the MRS.

The Preferred Alternative can change in response to public comment or new information.

COMMUNITY PARTICIPATION Detailed information regarding this proposed action is available in the Administrative Record File located at:

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Military Munitions Response Program Proposed Plan

Lake County Public Library Reference Section 1115 Harrison Avenue Leadville, CO 80461 Or The Camp Hale website at: http://www.camphale.org An announcement of the availability of this Proposed Plan was published in the Leadville Herald Democrat and Vail Daily newspapers on July 23, 2015, in accordance with CERCLA requirements.

The Army is seeking comments on the action recommended in this Proposed Plan. A public comment period running from July 24, 2015, to

August 24, 2015, is open during which comments will be accepted and considered prior to a final decision on the EFV MRS. In addition, a public meeting will be held, if requested. A comment form has been included at the end of this document to submit input on the Proposed Plan.

For additional information, please contact:

Adam Little, Project Manager [email protected]

Or by US Postal Service to: Adam Little, Project Manager Omaha District CENWO-PM-H 1616 Capitol Avenue Omaha, Nebraska 68102

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Military Munitions Response Program Proposed Plan

ACRONYMS AND ABBREVIATIONS ARAR ............Applicable or Relevant and Appropriate Requirement CDPHE ..........Colorado Department of Public Health and Environment CERCLA ........Comprehensive Environmental Response, Compensation, and Liability Act DD ..................Decision Document DERP .............Defense Environmental Restoration Program DMM..............Discarded Military Munitions DGM ..............digital geophysical mapping DoD ................Department of Defense EFV ................East Fork Valley FS ...................Feasibility Study FUDS .............Formerly Used Defense Sites FUDSMIS ......Formerly Used Defense Sites Management Information System HE ..................high explosive HEAT .............High Explosive Anti-Tank LUC................Land Use Control MC .................Munitions Constituents MD .................Munitions Debris MEC ...............Munitions and Explosives of Concern MMRP............Military Munitions Response Program mm .................millimeter MRS ...............Munitions Response Site NFS ................National Forest System NPL ................National Priorities List RAO ...............Remedial Action Objective RI....................Remedial Investigation TCRA .............Time Critical Removal Action TNT ................trinitrotoluene USACE ..........U.S. Army Corps of Engineers USEPA ...........U.S. Environmental Protection Agency USFS ..............U.S. Forest Service UXO ...............Unexploded Ordnance WRNF ............White River National Forest

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Military Munitions Response Program Proposed Plan GLOSSARY OF TERMS Administrative Record File – A compilation of documents that serve as the basis for the decision in selecting a response action to be taken at a site.

Applicable or Relevant and Appropriate Requirements (ARAR) – The Federal and State environmental laws that a selected remedy will meet. These requirements may vary among sites and alternatives.

Comprehensive Environmental Response Compensation, and Liability Act (CERCLA) – The Federal law that addresses problems resulting from releases of hazardous substances to the environment.

Decision Document (DD) – The CERCLA decision document that presents the cleanup remedy selected by the USACE.

Feasibility Study (FS) –a study undertaken by the lead agency to develop and evaluate options for remedial action. The RI data are used to define the objectives of the response action, to develop remedial action alternatives, and to undertake an initial screening and detailed analysis of the alternatives. The term also refers to a report that describes the results of the study.

Land Use Controls (LUC) – Physical, legal, or administrative mechanisms that restrict the use of, or limit access to, contaminated property to reduce risk to human health and the environment. Physical mechanisms encompass a variety of engineered remedies to contain or reduce contamination and physical barriers to limit access to property, such as fences or signs. The legal mechanisms are imposed to ensure the continued effectiveness of land use restrictions imposed as part of a remedial decision. Legal mechanisms include restrictive covenants, negative easements, equitable servitudes, and deed notices. Administrative mechanisms include notices, adopted local land use plans and ordinances, construction permitting, or other existing land use management systems that may

be used to ensure compliance with use restrictions.

Military Munitions – Ammunition products and components produced for or used by the armed forces for national defense and security. Military munitions used historically at the site include bulk explosives, hand grenades, rifle grenades, anti-tank practice landmines, rockets, mortars, and projectiles.

Munitions Constituents (MC) – Any materials originating from UXO, DMM, or other military munitions, including explosive and non-explosive materials, and emission, degradation, or breakdown elements of such ordnance or munitions.

Munitions and Explosives of Concern (MEC) – A specific category of military munitions that may pose unique explosives safety risks, and includes: (a) UXO; (b) DMM; or (c) MC (e.g., TNT, RDX) present in high enough concentrations to pose an explosive hazard.

Munitions Debris (MD) – Remnants of munitions (e.g., fragments, penetrators, projectiles, shell casings, links, fins) remaining after munitions use, demilitarization, or disposal.

Munitions Response – Response actions, including investigation, removal and remedial actions to address the explosives safety, human health, or environmental risks presented by UXO, DMM, or MC.

Munitions Response Site (MRS) – A discrete location that is known to require a munitions response.

National Priorities List (NPL) – USEPA’s list of uncontrolled or abandoned waste sites that present the greatest potential threat to human health or the environment.

Preferred Remedial Alternative – The remedial alternative selected by the Army and USEPA, based on a comparison of various remedial alternatives using specific evaluation criteria.

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Military Munitions Response Program Proposed Plan

Present Worth – The amount of money that would need to be invested in the current year, at a particular discount rate, to sufficiently evaluation criteria.

Proposed Plan – CERCLA document that summarizes evidence to support the selection of a preferred remedial alternative at a CERCLA site. The document is intended for public distribution to solicit comments on the proposed action(s).

Remedial Action Objectives (RAO) – Site-specific goals to protect human health and the environment.

Remedial Investigation (RI) – A process under CERCLA to determine the nature and extent of

the problem presented by a contaminant release. The RI includes sampling, monitoring, and gathering of sufficient information to determine the necessity for remedial action.

Unexploded Ordnance (UXO) – Military munitions that: (a) have been primed, fuzed, armed, or otherwise prepared for action; (b) have been fired, dropped, launched, projected or placed in such a manner as to constitute a hazard to operations, installations, personnel, or material; and (c) remain unexploded either by malfunction, design, or any other cause.

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Military Munitions Response Program Proposed Plan USE THIS SPACE TO WRITE YOUR COMMENTS Your input to the Proposed Plan process for the Military Munitions Response Program is important to the Army. The comments that the Army receives are vital to select the cleanup remedy for the site. Changes to the Preferred Remedial Alternative can be made based on comments made by the public. Please use the space below to submit your comments on the Proposed Plan. If you need more space for your comments, attach additional pages. After you have completed the form, mail to the following address: Adam Little, Project Manager [email protected]

Or by US Postal Service to: Adam Little, Project Manager Omaha District CENWO-PM-H 1616 Capitol Avenue Omaha, Nebraska 68102 Comments must be postmarked by August 24, 2015.

If you have any questions about the comment period, please contact Adam Little.

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