Draft Property Management Plan for the Designated Areas of

Draft Property Management Plan for the Designated Areas of Concerns 1 Ravenna Army Ammunition Plant 2

Ravenna, Ohio 3

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Prepared for: 7

Ohio Army National Guard 8 Camp Ravenna Joint Military Training Center 9

Ravenna, Ohio 10 11

National Guard Bureau 12 Arlington, VA 22206 13

14 U.S. Army Base Realignment and Closure Division 15

Ravenna Army Ammunition Plant 16 Ravenna, Ohio 17

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Prepared by: 21

22 U.S. Army Corps of Engineers 23

600 Dr. Martin Luther King Jr. Place 24 Louisville, Kentucky 40202 25

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August 10, 2010 28

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DISCLAIMER STATEMENT 5

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This report is a work prepared for the United States Government by the U.S. Army Corps of 7 Engineers. In no event shall either the United States Government or the U.S. Army Corps of 8

Engineers have any responsibility or liability for any consequences of any use, misuse, inability 9 to use, or reliance on the information contained herein, nor does either warrant or otherwise 10

represent in any way the accuracy, adequacy, efficacy, or applicability of the contents hereof. 11

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DOCUMENT DISTRIBUTION 2

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Name/Organization Number of Printed Copies

Number of Electronic Copies

J. Kimberly Harriz, NGB 0 1

Katie Tait, OHARNG 0 1

Mark Paterson, BRACD/ RVAAP Facility Manager 2 2

Eileen Mohr, Ohio EPA -NEDO 0 1

Mark Eldridge, INCOM AEC 0 1

Glen Beckham, USACE – Louisville District 0 1

REIMS 0 1

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NGB = National Guard Bureau 5 OHARNG = Ohio Army National Guard 6 Ohio EPA – NEDO = Ohio Environmental Protection Agency – Northeast District Office 7 REIMS = Ravenna Environmental Information Management System 8 BRAC/RVAAP = Base Realignment and Closure Department/Ravenna Army Ammunition Plant 9 USACE = United States Army Corps of Engineers 10 INCOM AEC = Installation Management Command Army Environmental Command 11

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This is a place holder Page 9

Intended to be removed and replaced in the Final document 10

With an OEPA Approval Letter 11

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TABLE OF CONTENTS 1

LIST OF FIGURES………………………………………………………………………………VI 2

LIST OF APPENDICES………………………………………………………………………...VI 3

LIST OF ACRONYMS & ABBREVIATIONS………………………………………………..VII 4

1.0 INTRODUCTION …………………………………………………………………………….1 5 1.1 PURPOSE………………………………………………………………………………….1 6

1.2 BACKGROUND INFORMATION………………………………………………………..1 7

1.3 IMPLEMENTATION OF THE PROJECT MANAGEMENT PLAN – ROLES AND 8 RESPONSIBILITIES………………………………………………………………………….3 9

2.0 GENERAL LAND USES AND CONTROLS………………………………………………4 10

3.0 ENFORCEMENT OF LAND USE CONTROLS .................................................................7 11

4.0 LAND USE CONTROL MECHANISMS AND TRAINING ..............................................8 12 4.1 ENGINEERING CONTROLS ............................................................................................8 13

4.1.1 Perimeter Fencing .......................................................................................................8 14

4.1.2 AOC/MRS Fencing/Warning Signs ............................................................................8 15

4.2 LAND USE CONTROL AWARENESS TRAINING ........................................................8 16

4.2.1 Standard Awareness Training .....................................................................................8 17

4.2.2 Training Materials .......................................................................................................8 18

4.2.3 Training Records .........................................................................................................8 19

5.0 MONITORING AND REPORTING ...................................................................................10 20

6.0 CERCLA 121(C) FIVE-YEAR REVIEWS .........................................................................11 21

7.0 MODIFICATIONS ................................................................................................................12 22

8.0 PMP PLAN APPROVALS....................................................................................................13 23

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FIGURES 1

Figure 1. General Location and Orientation of the RVAAP/Camp Ravenna

Figure 2. RVAAP Facility Map 2

APPENDICES 3

APPENDIX A LAND USE CONTROLS FOR AOCS/MRSS 4 A-1.1 BACKGROUND 5

A-1.2 PUBLICATIONS 6 A-1.3 SITE LOCATION AND DESCRIPTION 7

A-1.4 REMEDY OBJECTIVES 8

A-1.5 LAND USE CONTROLS 9

A-1.6 MONITORING AND REPORTING 10

A-1.7 NOTICE UPON CONVEYANCE 11

A-1.8 AMENDMENT OR TERMINATION 12

A-1.9 POINTS OF CONTACT 13

APPENDIX B AOC/MRS SITE INSPECTION FORM 14

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LIST OF ACRONYMS & ABBREVIATIONS 1

AOC Area of Concern 2 BGS Below Ground Surface 3 BRACD Base Realignment and Closure Division 4 CERCLA Comprehensive Environmental Response Compensation and Liability Act 5 CAMP RAVENNA Camp Ravenna Joint Military Training Center 6 CO Commanding Officer 7 DERP Defense Environmental Restoration Program 8 DFFO The Director’s Final Findings and Orders 9 DOD Department of Defense 10 FWGWMPP Facility-Wide Ground Water Monitoring Program Plan 11 FWSAP Facility-Wide Sampling and Analysis Plan 12 IAP Installation Action Plan 13 IRP Installation Restoration Program 14 LUC Land Use Controls 15 MC Munitions Constituents 16 MEC Munitions and Explosives of Concern 17 MMRP Military Munitions Response Program 18 MRS Munitions Response Site 19 NCP National Contingency Plan 20 NGB National Guard Bureau 21 OHARNG Ohio Army National Guard 22 OHIO EPA Ohio Environmental Protection Agency 23 ORC Ohio Revised Code 24 PMP Property Management Plan 25 RCO Range Control Officer 26 RCRA Resource Conservation and Recovery Act 27 RD Remedial Design 28 RDX Cyclonite Hexahydro 1,3,5-Trinitro-1,3,5-Triazine 29 REIMS Ravenna Environmental Information Management System 30 ROD Record of Decision 31 RVAAP Ravenna Army Ammunition Plant 32 SVOC Semi-Volatile Organic Compound 33 TNT 2,4,6-Trinitrotoluene 34 UCMJ Uniform Code of Military Justice 35 WBG Winklepeck Burning Grounds 36 WWII World War II 37 38

U.S. Army/Ohio Army National Guard/National Guard Bureau Property Management Plan for Camp Ravenna Joint Military Training Center (Camp Ravenna) and Ravenna Army Ammunition Plant (RVAAP)

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1.0 INTRODUCTION 1

1.1 PURPOSE 2

The procedures described in this Property Management Plan (PMP) are intended to 3 comply with the Department of Defense (DoD) policy on Land Use Controls (LUCs) 4 associated with environmental restoration activities and munition investigation/response 5 actions for an active installation. The purpose of this PMP is to serve as a formal tool to 6 help manage and set forth procedures for the LUCs established to protect human health 7 and the environment at each Area of Concern (AOC)/Munitions Response Site (MRS). 8 This PMP identifies the designated land use categories at the AOCs/MRSs at the 9 Ravenna Army Ammunition Plant (RVAAP), now known and operated as the Camp 10 Ravenna Joint Military Training Center (Camp Ravenna) by the Ohio Army National 11 Guard (OHARNG). Land uses were defined at the beginning of the environmental 12 restoration project. If residual contamination is left in place, the Record of Decision 13 (ROD) for the AOC/MRS requires the use of LUCs in accordance with the approved 14 Remedial Design (RD). This PMP is intended to capture all LUCs prescribed by the 15 approved RDs and document those AOCs/MRSs that do not require LUCs. This PMP 16 serves as a formal agreement between Ohio EPA and the US Department of the Army. 17 Appendix A shall include an individual section for each AOC/MRS documenting 18 whether a LUC is required or not. 19

These current land use categories are intended to implement decisions reached through 20 the Comprehensive Environmental Response, Compensation, and Liability Act 21 (CERCLA) [42 U.S.C. §9601, et seq.] risk-based decision process, as implemented 22 through the National Contingency Plan (NCP), 40 C.F.R. Part 300. The CERCLA NCP 23 process is employed consistent with the Final Findings and Orders issued by the Director, 24 Ohio Environmental Protection Agency (Ohio EPA), June 10, 2004. The Defense 25 Environmental Restoration Program (DERP) [10 U.S.C. §2701, et seq.] is also relevant to 26 the manner in which remediation will proceed, particularly with respect to safety issues 27 unique to munitions and explosives of concern (MEC). 28

This PMP will serve as a formal tool to help manage the LUCs established to protect 29 human health and the environment at each AOC/MRS. The AOC/MRS-specific 30 information in Appendix A is based upon the Final Record of Decision and the approved 31 RD for that specific AOC/MRS. Current copies of this PMP will be maintained by the 32 Garrison Commander, the Camp Ravenna Environmental Office and the RVAAP Base 33 Realignment and Closure Division (BRACD) Facility Manager. 34

1.2 BACKGROUND INFORMATION 35

When the RVAAP Installation Restoration Program (IRP) began in 1989, RVAAP was 36 identified as a 21,419-acre installation. The property boundary was resurveyed by 37 OHARNG over a 2-year period (2002 and 2003) and the total acreage of the property was 38


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found to be 21,683.289 acres. As of February 2006, a total of 20,403 acres of the former 1 21,683-acre RVAAP has been transferred to the National Guard Bureau (NGB) and 2 subsequently licensed to OHARNG for use as a military training site. 3

The current RVAAP consists of 1,280 acres scattered throughout Camp Ravenna. Camp 4 Ravenna is in northeastern Ohio within Portage and Trumbull Counties, approximately 3 5 miles (4.8 km) east-northeast of the City of Ravenna and approximately 1 mile (1.6 km) 6 northwest of the City of Newton Falls. The RVAAP portions of the property are solely 7 located within Portage County. RVAAP/Camp Ravenna is a parcel of property 8 approximately 11 miles (17.7 km) long and 3.5 miles (5.6 km) wide bounded by State 9 Route 5, the Michael J. Kirwan Reservoir, and the CSX System Railroad on the south; 10 Garret, McCormick, and Berry roads on the west; the Norfolk Southern Railroad on the 11 north; and State Route 534 on the east (Figures 1-1 and 1-2). Camp Ravenna is 12 surrounded by several communities: Windham on the north; Garrettsville 6 miles (9.6 13 km) to the northwest; Newton Falls 1 mile (1.6 km) to the southeast; Charlestown to the 14 southwest; and Wayland 3 miles (4.8 km) to the south. 15

When RVAAP was operational, Camp Ravenna did not exist and the entire 21,683-acre 16 parcel was a government-owned, contractor-operated industrial facility. The RVAAP IRP 17 encompasses investigation and cleanup of past activities over the entire 21,683 acres of 18 the former RVAAP. References to RVAAP in this document are considered to be 19 inclusive of the historical extent of RVAAP, which is inclusive of the combined acreages 20 of the current Camp Ravenna and RVAAP, unless otherwise specifically stated. 21

Industrial operations at the former RVAAP consisted of 12 munitions-assembly facilities 22 referred to as “load lines.” Load Lines 1 through 4 were used to melt and load 2,4,6-23 trinitrotoluene (TNT) and Composition B into large-caliber shells and bombs. The 24 operations on the load lines produced explosive dust, spills, and vapors that collected on 25 the floors and walls of each building. Periodically, the floors and walls were cleaned with 26 water and steam. Following cleaning, the waste water, containing TNT and Composition 27 B, was known as “pink water” for its characteristic color. Scupper systems were used to 28 collect pink water, which was contained in concrete holding tanks, filtered, and pumped 29 into unlined ditches for transport to earthen settling ponds. However, in some instances, 30 pink water was swept from doorways, or scupper systems overflowed onto the ground 31 surface. Load Lines 5 through 11 were used to manufacture fuzes, primers, and boosters. 32 Potential contaminants in these load lines include lead compounds, mercury compounds, 33 and explosives. From 1946 to 1949, Load Line 12 was used to produce ammonium nitrate 34 for explosives and fertilizers prior to use as a weapons demilitarization facility. 35

In 1950, the facility was placed in standby status and operations were limited to 36 renovation, demilitarization, and normal maintenance of equipment, along with storage of 37 munitions. Production activities were resumed from July 1954 to October 1957 and again 38 from May 1968 to August 1972. In addition to production missions, various 39 demilitarization activities were conducted at facilities constructed at Load Lines 1, 2, 3, 40 and 12. Demilitarization activities included disassembly of munitions and explosives 41 melt-out and recovery operations using hot water and steam processes. Periodic 42 demilitarization of various munitions continued through 1992. 43


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In addition to production and demilitarization activities at the load lines, other facilities at 1 RVAAP include AOCs/MRSs that were used for the burning, demolition, and testing of 2 munitions. These burning and demolition grounds consist of large parcels of open space 3 or abandoned quarries. Potential contaminants at these AOCs/MRSs include explosives, 4 propellants, metals, and waste oils. Other types of AOCs/MRSs present at RVAAP 5 include landfills, an aircraft fuel tank testing facility, and various general industrial 6 support and maintenance facilities. 7

1.3 IMPLEMENTATION OF THE PROJECT MANAGEMENT PLAN – ROLES 8 AND RESPONSIBILITIES 9

It is the responsibility of the Army to maintain and enforce LUCs at RVAAP. The 10 RVAAP BRACD Facility Manager will be responsible for maintenance of the LUCs until 11 they no longer have a presence at the site. Once the BRACD Facility Manager is no 12 longer present on RVAAP, NGB and OHARNG will then be responsible to maintain 13 these LUCs. 14


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2.0 GENERAL LAND USES AND CONTROLS 1

Land Use Controls (LUCs) include any type of physical, legal, or administrative 2 mechanisms that restrict use of, or limit access to, real property to prevent or reduce risks 3 to human health and the environment. Physical mechanisms encompass a variety of 4 engineered remedies to contain or reduce contamination and/or physical barriers to limit 5 access to the property, such as fences or signs. LUCs are used to mitigate risks 6 associated with exposure to contamination, when it is inappropriate or not feasible to 7 eliminate those risks by removing or treating the contaminated media to unrestricted use 8 levels. LUCs are often used as a component of other remedial actions. In many 9 circumstances LUCs are used when the alternative of leaving contaminants in place 10 proves to be the most favorable risk management decision (e.g., due to technical or 11 economic limitations, concerns regarding worker safety, or to prevent collateral 12 ecological damage). 13

Unlike many LUCs for other facilities, those developed for Camp Ravenna were based 14 upon the certain activities the OHARNG may perform on any particular AOC/MRS on 15 the Installation. The various Land Uses were established by evaluating all potential 16 exposures associated with a particular OHARNG receptor. In addition to the OHARNG 17 receptors and associated Land Uses, there are other standard Land Uses and receptors that 18 are commonly assessed in risk assessments such as the "resident". All receptors and the 19 input parameters used to evaluate their potential exposures were considered when 20 determining suitable Land Uses for an AOC/MRS. The specific exposure parameters and 21 the receptors can be found in the Human Health Risk Assessor's Manual (see RVAAP’s 22 Facility Wide Human Health Risk Assessor Manual Amendment 1. USACE. 1 Dec 2005) 23 and the RVAAP's Facility-wide Cleanup Goal Report (Final Facility-Wide Human 24 Health Cleanup Goals for Ravenna Army Ammunition Plant. SAIC. 23 Mar 2010). The 25 purpose of assessing risks to OHARNG specific receptors was to determine what 26 functions and Land Uses a particular AOC/MRS would meet for the OHARNG and if 27 there were any LUCs that were needed that would restrict OHARNG's activities on the 28 AOC/MRS in order to be protective. These LUCs essentially define what types of 29 activities or limits the OHARNG has associated with a particular Land Use at a specific 30 AOC/MRS. 31

LUCs, including activity limitations, associated specifically with any one RVAAP 32 AOC/MRS are discussed in Appendix A. The AOC/MRS-specific narrative in Appendix 33 A will be updated as necessary to support changes to the status of the AOCs/MRSs. 34 Updates are the responsibility of the RVAAP BRACD Facility Manager until BRACD no 35 longer has a presence at Camp Ravenna, after which update responsibility is delegated to 36 NGB and the OHARNG. 37

The LUCs for each AOC/MRS will be reviewed as specifically described for each in 38 Appendix A. All reviews (e.g., quarterly or as stated in the Appendix A) will be 39 documented in an Annual Report that will supplement the required five-year review 40 process under CERCLA’s Long Term Management requirements. It is anticipated that 41


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the frequency of the reviews and/or Annual Reports may be modified in the future, but 1 will be determined on an AOC/MRS specific-basis. 2

The specific Land Use categories for the AOCs/MRSs with general activity-based 3 restrictions at the RVAAP/Camp Ravenna are summarized below. Specific detailed land 4 use controls associated with the AOCs/MRSs in each Land Use category are provided in 5 Appendix A: 6

• Unrestricted Ohio Army National Guard: Details of this Land Use will be 7 determined at a later date. It is expected that a LUC will be required to ensure 8 the site remains strictly for Ohio Army National Guard Trainee use. 9

• Small Arms Range: Areas with this designation are intended for small arms 10 training, but are not limited to the use and practice of infantry weapons that an 11 individual soldier can carry into the field of battle. Small arms practice and use 12 during Camp Ravenna training activities may involve revolvers, pistols, 13 submachine guns, shot guns, carbines, assault rifles, sniper rifles, light to 14 general-purpose machine guns, and grenades. Use of the Mark-19 grenade 15 machine gun and multi-purpose machine guns using non-high explosive 40-16 millimeter practice rounds or smaller caliber are included in this designated 17 land use, but other weapons may be used as well. Areas with the “Small Arms 18 Range” designation that are also within an AOC/MRS may have digging 19 restrictions. Those digging restrictions are described in the AOC/MRS-20 specific language in Appendix A. 21

• Dismounted Training – Digging (7’): Areas with this designation, which are 22 also within AOCs/MRSs, have restrictions for digging to depths greater than 7 23 feet below ground surface (bgs). This restriction is due to the potential for 24 encountering residual contamination. In AOCs/MRSs with this restriction, 25 dismounted training and digging up to seven feet bgs is permitted. Tracked 26 and wheeled operations are permitted only as directed in section 16, AGO Pam 27 210-1. 28

• Mounted Training – No Digging: Per the Human Health Risk Assessors 29 Manual, Direct contact is permitted w/ soil and/or water up to 24 hrs/day, 24 30 days/year on inactive duty training and/or 24 hrs/day, 15 days/yr during annual 31 training w/ no ill effect to the soldier. All digging is prohibited in this area. 32 Digging and occupying fighting positions, tank defilade positions, tank ditches 33 and battle positions that extend below ground surface are prohibited. Tracked 34 and wheeled operations are permitted only as directed in section 16, AGO Pam 35 210-1. Maneuver damage of up to 4’ below ground surface. 36

• Restricted Access – Authorized Personnel Only: Areas with this designation 37 are closed to all normal training activities. Surveying, sampling and other 38 essential security, safety, environmental, natural resources management, and 39 other permitted activities may be conducted here only after personnel have 40 been authorized by the U.S. Army entity responsible for the AOC/MRS. All 41


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personnel must be properly briefed on potential hazards and sensitive areas. 1 Individuals unfamiliar with the hazards and controls will be escorted by 2 authorized personnel at all times while in the restricted area. Camp Ravenna 3 command staff or designees will brief OHARNG personnel, including full-time 4 staff, contractors, training and logistics personnel, and visiting units regarding 5 restricted areas. The RVAAP BRACD Facility Manager or their designee will 6 continue to brief contractors hired to conduct investigations or perform 7 remedial work. 8


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3.0 ENFORCEMENT OF LAND USE CONTROLS 1

All Army and OHARNG/Camp Ravenna personnel and authorized visitors to the 2 installation will comply with the prescribed LUCs, including land use limitations. If the 3 Army or OHARNG/Camp Ravenna personnel observe a LUC violation, they will 4 immediately take appropriate corrective action (e.g., halt excavation operations, 5 apprehend trespasser(s), take appropriate action to safely remove trespassers from 6 unauthorized areas, etc.). Any observed LUC violations will be reported to the RVAAP 7 BRACD Facility Manager or OHARNG CO (once BRACD no longer has a presence) 8 within 48 hours, or as soon as practicable. The RVAAP BRACD Facility Manager, in 9 consultation with the Camp Ravenna CO, will take action to restore the integrity of the 10 LUC, and will assess whether any additional preventive measure(s) should be considered 11 as a result of the reported incident (e.g., repair fence, post signs, publish further command 12 guidance, prosecute trespassers, etc.). 13

Administrative corrective measures should be sufficient to resolve most LUC violations 14 (e.g., verbal or written counseling, administrative sanctions against contractors, etc.). 15 However, in the event of a more egregious trespass or a repeat offender, offenders may 16 be subjected to administrative action or punishment under the Uniform Code of Military 17 Justice (UCMJ) for military personnel or title 18 U.S.C. 1382 and title 50 U.S.C. 797 for 18 civilians. Additionally, the Ohio State Code of Military Justice, Ohio Revised Code 19 (ORC) Chapter 5924 [or other state military code, as appropriate], can be applied if a 20 violation is alleged to have been committed by a Soldier or other uniformed personnel 21 subject to the UCMJ or deemed in violation of military law. 22

Since civilian personnel are not subject to military law, any sanctions imposed against 23 civilians will be based upon applicable federal and state laws and regulations. Criminal 24 sanctions may be considered for, but not limited to, such acts as unauthorized hunting 25 (OAC Chapters 1531 and 1533; 1547.69, 2923.16 and 4519.40 ORC), trespassing (ORC 26 2911.12), and attempted theft of scrap (ORC 2913.01 (K)). 27

If the Army discovers any land use that is inconsistent with LUC objectives or practices, 28 and/or that impairs the effectiveness of remedial actions at an AOC/MRS, the Army will 29 notify Ohio EPA in writing as soon as practicable, but no later than ten (10) calendar 30 days after discovery, with a written description of the inconsistent land use. Within ten 31 (10) calendar days after such notification, the Army will provide Ohio EPA with 32 information regarding what efforts or measures have been or will be taken to address the 33 inconsistent land use. 34


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4.0 LAND USE CONTROL MECHANISMS AND TRAINING 1

4.1 ENGINEERING CONTROLS 2

4.1.1 Perimeter Fencing 3

Public access to Camp Ravenna is limited. The installation is surrounded by a chain-4 link perimeter fence. The perimeter fence will be maintained indefinitely by the 5 Army unless it is determined not be necessary to have secure fencing to deter 6 unauthorized access to the facility. Such determination shall be coordinated with and 7 approved by the Ohio EPA and all Stakeholders. 8

4.1.2 AOC/MRS Fencing/Warning Signs 9

Some AOCs/MRSs may require an AOC/MRS fence, warning signs or Seibert stakes 10 as part of a LUC. These requirements will be specified in Appendix A of this PMP. 11

4.2 LAND USE CONTROL AWARENESS TRAINING 12

4.2.1 Standard Awareness Training 13

LUC awareness training will be provided to all appropriate individuals (eg, personnel, 14 visitors, visiting units) before they are granted access to any area with a LUC. The 15 training will be conducted by the Army or OHARNG. The LUC training will provide 16 an overview of this PMP and the procedures for preventing and reporting LUC 17 violations, as well as any AOC/MRS specific restrictions. An annual refresher course 18 will also be provided. Standard in-processing of newly assigned permanent party and 19 contract employees shall include the standard LUC awareness training if the 20 individual will be accessing any area with a LUC. 21

4.2.2 Training Materials 22

This PMP shall serve as the basis of all LUC awareness training materials. Appendix 23 A includes the AOC/MRS specific LUC information. 24

4.2.3 Training Records 25

Documentation of training sessions will be kept on record for future reference and to 26 supplement inspections and the CERCLA Five-Year Review for each AOC/MRS. 27 Each training record will annotate the date, time, location, instructor(s), name of 28


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audience (e.g. X-Company, Unit, Group, platoon, etc.), title of training, and what 1 AOCs/MRSs are likely to be involved for purposes of awareness during field training 2 activities. 3


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5.0 MONITORING AND REPORTING 1

Site inspections will be conducted by the Army or OHARNG to confirm if the LUCs 2 remain effective and meet LUC objectives for continued remedy protectiveness. Site 3 inspections will be conducted periodically, as directed by the AOC/MRS-specific RD. At 4 a minimum, a LUC AOC/MRS Inspection Form located in Appendix B of this PMP will 5 be completed for each periodic inspection. Results from periodic inspections will be 6 reported in an annual LUC monitoring report, with changes in inspection frequency to be 7 coordinated with and approved by Ohio EPA. 8

The annual LUC monitoring report will evaluate the status and effectiveness of LUCs 9 with a description of how any LUC deficiencies, including inconsistent land uses, were 10 addressed. The annual LUC monitoring reports will be used in the preparation of the 11 CERCLA 121(c) Five-Year Review. The annual LUC monitoring report will include a 12 written certification stating whether or not the LUCs remain in place and are effective. 13

Inspections will be conducted according to the frequency cited within the RD and 14 Appendix A for the AOCs/MRSs listed in this PMP. The inspection form will be 15 prepared by the Army; approved by the Camp Ravenna Commander (or their assigned 16 designee) and Ohio EPA. The LUC AOC/MRS Inspection Form located in Appendix B 17 of this PMP will be used to support the preparation of the Annual Report (summarizing 18 current status of land use classification and LUCs) for each AOC/MRS covered by this 19 PMP. 20


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6.0 CERCLA 121(C) FIVE-YEAR REVIEWS 1

As part of the CERCLA Section 121(c) Five-Year remedy review process, the Army shall 2 prepare a report evaluating the continued effectiveness of the remedy, including 3 effectiveness of the LUCs and an assessment of whether there is a need to modify the 4 LUCs. 5

The Army will verify whether the LUCs continue to be properly documented and 6 maintained. Each remedy review will evaluate whether conditions have changed due to 7 contaminant attenuation, migration or other factors such as land use. Such changes will 8 be investigated to the extent deemed necessary, depending on the AOC/MRS conditions. 9 If the risk levels have changed since initial LUC implementation, LUC modifications will 10 be considered, which may include a change in monitoring frequency. 11


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7.0 MODIFICATIONS 1

Any modifications to this PMP will be provided to all stakeholders for their comment and 2 approval. Any modifications must be documented in a manner to demonstrate that all 3 LUCs presented herein are properly maintained throughout the Installation. 4

The current lead Army agency will provide notice of modification(s) to the Ohio EPA for 5 review, comment, and approval, prior to implementation of the proposed modification. 6 “Change pages” will be appropriately marked, and will identify the effective date. The 7 most current version of the PMP will be maintained by the Army and available on the 8 Ravenna Environmental Information Management System (REIMS) and/or the current 9 repository. 10

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8.0 PMP PLAN APPROVALS 1

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APPROVED: 4

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_________________________________________________________Date: _________ 6

Mark Patterson 7 RVAAP BRACD Facility Manager 8

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_________________________________________________________Date: __________ 11 XXXXXXX 12 Ohio Army National Guard 13

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_________________________________________________________Date: _________ 16

XXXXXXX 17 National Guard Bureau 18 19

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Figure 1. General Location and Orientation of the RVAAP/Camp Ravenna


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APPENDIX A 9

LAND USE CONTROLS FOR AOCS/MRSS 10

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A - 1

Appendix A-1: Winklepeck Burning Grounds – (RVAAP-005) 1

A-1.1 BACKGROUND 2

The total burning ground area consists of approximately 200 acres and has been in 3 operation since 1941. Prior to 1980, burning was conducted on the bare ground and the 4 ash was abandoned at the site. Wastes treated in the area included RDX, antimony 5 sulfide, Composition B, lead azide, TNT, propellants, black powder, waste oil, sludge 6 from the load lines, domestic wastes and small amounts of laboratory chemicals. From 7 1980 until 1998, periodic burning of scrap explosives, propellants, and explosive-8 contaminated waste materials (e.g. wipe rags, paper, cardboard) was conducted in raised 9 refractory-lined metal trays within a 1.5-acre area. A Part-B permit covering the active 10 portion of the site was withdrawn in 1994. The burn-trays along the 90-day storage unit, 11 Building 1601, were closed in accordance with Ohio EPA guidance in 1998. MEC is 12 present in the AOC. 13

A-1.2 PUBLICATIONS 14

The following publications can be located on www.RVAAP.org or in established 15 information repositories. 16

• Final Remedial Action Completion Report for RVAAP- 05 Winklepeck Burning 17 Grounds Pads 61/61A, 67, and 70 at Ravenna Army Ammunition Plant. MKM 18 Engineers. 19 Nov 2009. 19

• Final Contractor Quality Control Plan for the Remedial Action at RVAAP- 05 20 Winklepeck Burning Grounds at Ravenna Army Ammunition Plant. MKM 21 Engineers. 17 Nov 2008. 22

• Final Explosives Safety Submission for the Munitions and Explosives of Concern 23 Survey and Munitions Response of RVAAP- 05 Winklepeck Burning Grounds at 24 Ravenna Army Ammunition Plant, Revision 3, Amendment 3. MKM Engineers. 25 9 Oct 2008. 26

• Final Project Management Plan for RVAAP-05 Winklepeck Burning Grounds 27 Remedial Design/Remedial Action, Revision 2. MKM Engineers. 4 Sept 2008. 28

• Final Record of Decision for Soil and Dry Sediment at RVAAP- 05 Winklepeck 29 Burning Grounds at Ravenna Army Ammunition Plant. SAIC. Aug 2008. 30

• Final Remedial Action Work Plan for RVAAP-05 Winklepeck Burning Grounds 31 at Ravenna Army Ammunition Plant. MKM Engineers. 27 July 2008. 32

• Revised Final Report On The Biological Field-Truthing Effort At Winklepeck 33 Burning Grounds At Ravenna Army Ammunition Plant, Ravenna, Ohio. SAIC. 34 Aug 2006. 35

http://www.rvaap.org/docs/pub/F_PMP_WBG_RD_RA_R2.pdf�

http://www.rvaap.org/docs/pub/F_PMP_WBG_RD_RA_R2.pdf�

http://www.rvaap.org/docs/pub/FINAL_WBG_ROD_080708.pdf�

http://www.rvaap.org/docs/pub/FINAL_WBG_ROD_080708.pdf�

http://www.rvaap.org/docs/pub/BIO_FLD_TRUTH_FINAL/BIO_FLD_TRUTH_FINAL_MAIN.pdf�

http://www.rvaap.org/docs/pub/BIO_FLD_TRUTH_FINAL/BIO_FLD_TRUTH_FINAL_MAIN.pdf�

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• Final Sampling and Analysis Plan Addendum No. 2 for RVAAP-05 Winklepeck 1 Burning Grounds Feasibility Study. SAIC. Feb 2006. 2

• Proposed Plan for the Winklepeck Burning Grounds, Ravenna Army 3 Ammunition Plant, Ravenna, Ohio. SAIC. Dec 2005. 4

• Final Site Safety and Health Plan for the Phase II MEC Clearance and Munitions 5 Response at RVAAP-05 Winklepeck Burning Grounds. MKM Engineers. March 6 2005. 7

• Final Work Plan for Phase II MEC Clearance and Munitions Response at 8 RVAAP-05 Winklepeck Burning Grounds. MKM Engineers. March 1, 2005. 9

• Revised Final Focused Feasibility Study for RVAAP-05 Winklepeck Burning 10 Grounds. SAIC. March 2005. 11

• Final Phase I MEC Density Survey After Action Report at RVAAP-05 12 Winklepeck Burning Grounds. MKM Engineers. 1 March 2005. 13

• Final Phase II Remedial Investigation Report for the Winklepeck Burning 14 Grounds at RVAAP. SAIC. April 2001. 15

• Final Sampling and Analysis Plan and Site Safety and Health Plan Addendum 16 No. 1 for the Winklepeck Burning Grounds Feasibility Study. SAIC. Oct 2000. 17

• Closure, Completion of Partial Closure of RVAAP-07 Building 1601 Hazardous 18 Waste Storage and RVAAP-05 Winklepeck Burning Grounds (WBG). Ohio 19 EPA. 5 May 1999. 20

• Final Resource Conservation and Recovery Act (RCRA) Closure Field 21 Investigation Report for the Deactivation Furnace Area, Open Detonation Area, 22 Building 1601, and Pesticides Building at RVAAP. SAIC. June 1998. 23

• Final Sampling and Analysis Plan Addendum for the Phase II Remedial 24 Investigation of the Winklepeck Burning Grounds and Determination of Facility-25 Wide Background at the Ravenna Army Ammunition Plant. SAIC. April 1998. 26

• Phase I Remedial Investigation Report for High Priority Areas of Concern at the 27 Ravenna Army Ammunition Plant, Ravenna, Ohio. Final. SAIC. Feb 1998. 28

• Final Public Meeting Briefing Phase I Remedial Investigation of High Priority 29 Areas of Concern at the Ravenna Army Ammunition Plant. SAIC. Sept 1997. 30

• Final Phase I Remedial Investigation Site Safety and Health Plan Addendum for 31 High Priority Areas of Concern for the Ravenna Army Ammunition Plant. SAIC. 32 July 1996. 33

http://www.rvaap.org/docs/pub/WBG_FS_Final_Add_2_SAP_2006.pdf�

http://www.rvaap.org/docs/pub/WBG_FS_Final_Add_2_SAP_2006.pdf�

http://www.rvaap.org/docs/pub/WBG_PP_Final.pdf�

http://www.rvaap.org/docs/pub/WBG_PP_Final.pdf�

http://www.rvaap.org/docs/pub/WBG_SSHP_Final_PhaseIIMEC_2005.pdf�

http://www.rvaap.org/docs/pub/WBG_SSHP_Final_PhaseIIMEC_2005.pdf�

http://www.rvaap.org/docs/pub/WBG_WP_Final_PhaseIIMEC_2005.pdf�

http://www.rvaap.org/docs/pub/WBG_WP_Final_PhaseIIMEC_2005.pdf�

http://www.rvaap.org/docs/pub/WBG_FFS_rev_Final_2005.pdf�

http://www.rvaap.org/docs/pub/WBG_FFS_rev_Final_2005.pdf�

http://www.rvaap.org/docs/pub/WBG_PhaseIAfterAct_Final_2005.pdf�

http://www.rvaap.org/docs/pub/WBG_PhaseIAfterAct_Final_2005.pdf�

http://www.rvaap.org/docs/pub/P2_RI_WBG_Final/P2_RI_WBG_Final_TOC.pdf�

http://www.rvaap.org/docs/pub/P2_RI_WBG_Final/P2_RI_WBG_Final_TOC.pdf�

http://www.rvaap.org/docs/pub/WBG_FS_PLANS/Final_SAP_SSHP_ADD1_WBGFS.pdf�

http://www.rvaap.org/docs/pub/WBG_FS_PLANS/Final_SAP_SSHP_ADD1_WBGFS.pdf�

http://www.rvaap.org/docs/pub/Closure_B1601_OBG.pdf�

http://www.rvaap.org/docs/pub/Closure_B1601_OBG.pdf�

http://www.rvaap.org/docs/pub/RCRA_CLOSURE_DFA_ODA_1601.pdf�



http://www.rvaap.org/docs/pub/P2_RI_PLANS_WBG.pdf�



http://www.rvaap.org/docs/pub/P1_RI_HP_AOCS_Final/PI_RI_HP_AOCS_Final_TOC.pdf�

http://www.rvaap.org/docs/pub/P1_RI_HP_AOCS_Final/PI_RI_HP_AOCS_Final_TOC.pdf�

http://www.rvaap.org/docs/pub/P1_RI_BRIEF_HP_AOCS.pdf�

http://www.rvaap.org/docs/pub/P1_RI_BRIEF_HP_AOCS.pdf�

http://www.rvaap.org/docs/pub/P1_RI_Plans_HP_AOCS.pdf�


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• Final Phase I Remedial Investigation Sampling and Analysis Plan Addendum for 1 High Areas of Concern for the Ravenna Army Ammunition Plant. SAIC. July 2 1996. 3

• Final Quality Control Plan for the Phase I Remedial Investigation for High Areas 4 of Concern at RVAAP. SAIC. June 1996. 5

6



http://www.rvaap.org/docs/pub/P1_RI_QCP_HP_AOCS.pdf�

http://www.rvaap.org/docs/pub/P1_RI_QCP_HP_AOCS.pdf�

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A-1.3 SITE LOCATION AND DESCRIPTION 1

WBG encompasses approximately 200 acres in the central portion of RVAAP as 2 illustrated within Figure1 of this PMP and Figure A-1 of this Appendix. The WBG tract 3 of land exists in an open field within a gently rolling plain having a west to east run-off 4 gradient with a network of looping gravel roads traversing past the once used burning pad 5 areas. The former WBG is now under the administrative control of the NGB. It is 6 classified as a small arms range. The training area was designed to support training with 7 such weapons as the 40mm MK-19 machinegun fire using target practice rounds. 8

A-1.4 REMEDY OBJECTIVES 9

Where applicable, the previously applied remedy consisted of excavation of 10 contaminated soil to preclude likely exposure through human contact at the WBG. A 11 portion of that remedy resulted in hazardous substances, pollutants, or contaminants 12 remaining above levels that allow unlimited use and unrestricted exposure. Therefore a 13 component of the remedial action includes land use controls (see item 6 below). Because 14 LUCs will be used as part of the remedy, any property owner subsequent to the NGB will 15 be required to enter into an environmental covenant pursuant to Ohio State House Bill 16 516 that meets the requirements of ORC ¶ 5301.82. 17

A-1.5 LAND USE CONTROLS 18

• Land use of the WBG AOC shall be limited by the maintenance of the existing 19 Camp Ravenna perimeter fence. 20

• The designated WBG AOC land use is for Small Arms Range (including the 21 existing Mark 19 Grenade Machinegun Range) training. The activities on the 22 WBG AOC shall be limited to the following: 23

o target practice 24

o maintenance of targetry and associated lifting mechanisms 25

o range maintenance including, but not limited to, such activities as removal 26 of target practice rounds from the ground surface within the impact area 27 and clearing of target practice rounds from the surface of the range area 28

o road and culvert repair 29

o routine ditch maintenance 30

o vegetation management; e.g., mowing, brush and weed cutting, controlled 31 burning, and herbicide application 32

o compatible natural resources management activities including but not 33 limited to such activities as flora and fauna surveys and timber 34 management (e.g., timber stand improvement, forest products harvesting, 35

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soil stabilization and erosion control, and invasive/non-native species 1 control) 2

o nuisance wildlife control 3

o drainage maintenance 4

o wetland delineations 5

o grassland management 6

o scientific research 7

o sampling 8

• Determination of the LUCs was based on specific parameters developed for 9 personnel exposure established for the National Guard Range Maintenance 10 Soldier exposure scenario cited at 85 days per year at 6 hours per day for a 11 maximum of 25 years (reference RVAAP Facility-Wide Human Health Risk 12 Assessor Manual with Amendment 1 – USACE 2005). 13

• All activities executed within the WBG confines must be in compliance with 14 OHARNG range safety regulations, established digging restrictions, and 15 established exposure limits. In accordance with current Department of Army 16 regulations, the small arms range will be marked with signage, facing outward, to 17 warn personnel that the area is a live fire range. All other uses of the WBG AOC 18 are prohibited. 19

• Ground water use or extraction of groundwater located at or underlying the WBG 20 AOC or any portion thereof is prohibited, except for the following: 21

o The installation, development, purging, and sampling of new or existing 22 monitoring wells in accordance with the most recent Facility-Wide 23 Sampling and Analysis Plan (FWSAP) as part of the AOC-specific IRP or 24 Facility-Wide Ground Water Monitoring Program Plan (FGWMPP) 25

o The abandonment and replacement of monitoring wells damaged by on-26 installation activities, and wells no longer utilized as part of IRP or 27 FGWMPP activities, in accordance with Ohio EPA guidance, the most 28 recent FWSAP and applicable Ohio Administrative Code requirements. 29

• Disturbance Activity and Use Limitations: All digging or excavation on the 30 WBG AOC outside of the UXO/MEC-cleared areas within the Mark 19 Grenade 31 Machinegun Range is prohibited with the following exceptions: 32

o Routine maintenance of roads, ditches, and culverts. 33

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o Ground surface repairs by authorized range personnel in support of 1 authorized range activities. 2

o Digging along target array areas by authorized range personnel (e.g. 3 Range Maintenance Soldier) to a depth of 1 foot below ground surface. 4

A-1.6 MONITORING AND REPORTING 5 Periodic monitoring of LUCs in the form of site inspections will be conducted by the 6 Army to confirm whether the LUCs remain effective and meet LUC objectives for 7 continued remedy protectiveness. Site inspections will be conducted on a quarterly basis. 8 9 Monitoring results will be reported in an annual LUC monitoring report, with changes in 10 monitoring frequency to be coordinated with and approved by Ohio EPA. The Army will 11 provide (via mail) each report to Ohio EPA. 12 13 The annual LUC monitoring report will evaluate the status and effectiveness of LUCs 14 with a description of how any LUC deficiencies or inconsistent uses were addressed. The 15 annual LUC monitoring reports will be used in part for the preparation of the CERCLA 16 121(c) Five-Year Review. As part of the LUC monitoring report, a written certification 17 will be submitted stating whether or not the LUCs remain in place and are effective. 18

A-1.7 NOTICE UPON CONVEYANCE 19

Owner and all assigns and successors of interest conveying any interest in the property or 20 any portion of the property shall provide a notice of the LUCs set forth as part of the 21 WBG AOC ROD and RD, and attach the same to the transfer documents and recorded 22 deed. 23

Owner shall notify Ohio EPA and any ‘Holders’ other than the Owner within ten calendar 24 (10) days after each conveyance of an interest in any portion of the Property. Owner’s 25 notice shall include the name, address, and telephone number of the Transferee, a copy of 26 the deed or other documentation of the conveyance, and a survey map that shows the 27 boundaries of the property being transferred. 28

A-1.8 AMENDMENT OR TERMINATION 29

This PMP is intended to be enforceable by the Ohio EPA pursuant to the applicable 30 RODs and RDs, which were prepared in accordance with the Director’s Final Findings 31 and Orders (DFFO) for RVAAP. The PMP’s purpose of subjecting the WBG AOC to 32 LUCs may be amended or terminated by consent of all of the following: the Owner or a 33 Transferee; other Holders; and the Ohio EPA. Amendment shall mean any changes to 34 the PMP, including the LUCs set forth under Appendix A, WBG, Section A-1.5 Land 35 Use Controls above, or the elimination of one or more LUCs when there is at least one 36 limitation remaining. Termination shall mean the elimination of all LUCs set forth herein 37 and all other obligations under this PMP. 38

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The PMP may be amended or terminated only by a written instrument duly executed by 1 the Director of Ohio EPA and the Owner or Transferee, and other Holders, of the 2 property or portion thereof, as applicable. 3

Within thirty (30) days of signature by all requisite parties on any amendment or 4 termination of WBG AOC PMP, the Owner or Transferee shall file such instrument for 5 recording with the Portage County Recorder’s Office, and shall provide a file- and date-6 stamped copy of the recorded instrument to Ohio EPA. 7

A-1.9 POINTS OF CONTACT 8

There are four Points of Contact for RVAAP. These are listed in the following. 9

Site Coordinator, RVAAP Division of Emergency and Remedial Response Ohio EPA, Northeast District Office 2110 East Aurora Road Twinsburg, Ohio 44087 (330) 963-1200

United States Property and Fiscal Officer for Ohio 2811 W. Dublin-Granville Road Columbus, OH 43235-2788 (614) 336-7201

RVAAP BRACD Facility Manager Bldg 1037 8451 State Route 5 Ravenna, OH 44266-9297 (330) 358-7312/Fax 7314

Camp Ravenna Commander Camp Ravenna Joint Military Training Center 1438 State Route 534 SW Newton Falls, OH 44444 (614) 336-6560

10

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1

2

1

2

3

4

5

6

7

8

APPENDIX B 9

AOC/MRS SITE INSPECTION FORM 10

11

12

13

14

15

16 17

18

19

20

Camp Ravenna Joint Military Training Center (Camp Ravenna) / 1 Ravenna Army Ammunition Plant (RVAAP) 2

LUC AOC/MRS Inspection Form 3 4

In accordance with the Camp Ravenna Joint Military Training Center/Ravenna Army 5 Ammunition Plant Property Management Plan (PMP) dated and Appendix 6 A-___ an inspection of AOC /MRS_________ was conducted by ___________________ 7 [indicate Army or its approved representative] on

Description of any observed Land Use Control (LUC) violation(s) 9

date. 8

___________________________________________________________________________10 ___________________________________________________________________________11 ___________________________________________________________________________12 __________________ 13

Date(s) of Notifications:______________________________________________________ 14

Description of any corrective actions taken to remedy observed LUC violation(s) 15

___________________________________________________________________________16 ___________________________________________________________________________17 ___________________________________________________________________________18 __________________ 19

20

Status of LUC Procedures 21 22

• AOC/MRS Map – Is the AOC/MRS map current with respect to AOC/MRS boundaries, 23 land activities and prescribed LUCs? 24

___________________________________________________________________________25 ___________________________________________________________________________26 ___________________________________________________________________________27 __________________ 28 29

• Fence, Sign and Gate Conditions – Are the installation perimeter fence and gates being 30 maintained and in good repair? Are the required Seibert stakes and/or signage in place 31 and functional? If not, when and what corrective actions will be undertaken? 32

___________________________________________________________________________33 ___________________________________________________________________________34 ___________________________________________________________________________35 __________________ 36

1

• Training – Was the LUC Awareness training consistently conducted over the past year? 2 If not, why not? What corrective actions were initiated? Who provided training? 3

___________________________________________________________________________4 ___________________________________________________________________________5 ___________________________________________________________________________6 __________________ 7

8

• Required Monitoring – Did the Army or the designated representative conduct required 9 monitoring over the past year? If not, why not. Provide dates of inspection. 10

___________________________________________________________________________11 ___________________________________________________________________________12 ___________________________________________________________________________13 __________________ 14

15

16

Date: 17

Name/Title: 18

Organization: 19

Signature: __________________ 20

Documents

Draft Property Management Plan for the Designated Areas of