A. Background Information
- FBH is located approximately 12 miles from downtown Indianapolis, Indiana, in Lawrence Township, Marion County, Indiana. It is bounded by residential areas and farmland, except light industrial areas that border FBH to the southeast. The landscape at FBH consists of moderately sloping terraces that rise from nearly level bottomland along Fall Creek and its tributaries to nearly level uplands. Sensitive environments at FBH include various wetlands, habitat areas for the endangered Indiana bat and several species of endangered plants, sites of archaeological investigations, historically significant buildings, and the site of a private cemetery.
- FBH contains 2,501 acres, of which approximately 1,069 acres is covered by woodlands.
- This information is not currently available.
- FBH is located on 2,501 acres in Lawrence Township, Marion County, Indiana, approximately 12 miles northeast of downtown Indianapolis. Most of the land adjacent to FBH is residential.
- FBH was created by an act of Congress on March 3, 1903. The initial land purchase for the present installation location, however, was not made until June 1904, when the Army purchased 1,994 acres. The Army also purchased an additional 423 acres in 1908 and 1909 south of the installation to allow military access to the "Big Four Railroad" prior to its purchase for military purposes at FBH, the land was used primarily for farming.
- From 1906 to 1908, FBH was used jointly by the regular Army and the National Guard as training grounds. Infantry regiments were stationed at FBH for garrison duty from the summer of 1908 to the winter of 1913. FBH was abandoned from the winter of 1913 until the spring of 1917. From 1917 to 1919, an Officer Training Camp, a Medical Officer's Training Camp, and an Engineer Training Camps were held at FBH to support the effort of World War I.
- The 11th Infantry Regiment was stationed at FBH from 1922 to 1941. A Citizen Military Training Camp was held at FBH from 1925 to 1941. The Civilian Conservation Corps Reforestation Act of 1933 established a Civilian Conservation Corps at FBH from 1933 to 1941.
- From 1940 to 1945, FBH became the site of an induction/reception center for military draftees, the Army Finance School, the Chaplain School, a school for bakers and cooks, the Finance Replacement Training Center, a prisoner of war camp, and an Army disciplinary barracks. A 1,000-bed hospital, Billings General Hospital, was built at FBH in 1941. Following the end of hostilities in 1945 and into early 1947, activities at FBH were slowly phased out. Billings general Hospital was closed in March 1946 and the Finance School moved to St. Louis in July 1946. On July 1, 1947, FBH was officially declared "United States Army surplus," but in August 1947, it was returned to active status as a permanent military post. In October 1948, command of FBH was relinquished to the 10th Air Force for use as an Air Force Installation. It was determined, however, that the facilities at FBH were inadequate to house an air force base, and in April 1950, command of FBH was returned to the Army.
- The 1950s at FBH were marked by reactivation and construction activities. In 1953 and 1954, the Benjamin Harrison Village Corporation built 300 apartment buildings on the southwest side of the post, which FBH purchased in April 1960 for use as military housing. Building 400, later to be named the Gates-Lord Hall, was constructed from November 1954 to February 1957 to house the new Adjutant General and Finance Schools.
- The Army Finance Center was constructed at the site of the former Army airfield from August 1951 to October 1953. The activities that followed the opening of the Army Finance Center at FBH can be characterized as administration and training. In 1966, FBH opened the Defense Information School. In 1971, FBH was designated the United States Army Administrative Schools Center, and in 1973, it was redesignated the United States Army Administrative Center (ADMINCEN) which was one of three mid-management centers for combat developments. In 1973, ADMINCEN was associated with schools such as the Chaplain School, the Woman's Army Corps School, the Defense Information School, the Defense Language Institute, the Judge Advocate General School, the Academy of Health Sciences, the Army Element of the Naval School of Music, and the Institute of Administration.
- In the past, the Soldier Support Center at FBH included the Adjutant General School, the Finance School, the Recruiting and Retention School and the Army Element of the Naval School of Music, the Chaplain Center and School, the Judge Advocate General's School and the Defense Information School. Six major tenant commands, including the Defense Finance and Accounting Service - Indianapolis Center, the Enlisted Records and Evaluation Center, Hawley Army Community Hospital, the Readiness Group Harrison, and the 123rd Army Reserve Command was also located at FBH. In April 1991, FBH was recommended for closure by the Secretary of Defense as part of Installation Closure 91, with approval for closure in October 1991. The Defense Finance and Accounting Service - Indianapolis Center was transferred from the Department of the Army to the Department of Administration in 1995.
- The 123rd Army Reserve Command will continue to operate on the eastern portion of the base. Closure plans were implemented and on September 30, 1995 the Fort cease operation as a Fort. As of November 1, 1995, the base should be referred to as a U.S. Army Garrison.
- FBH provided support for the U.S. Army Financial and Accounting Center, the U.S. Army Administration Center, the Defense Information School, the U.S. Army Enlisted Records and Evaluation Center and other tenant activities. That mission ceased on September 30, 1995. The mission of the few staff remaining is to complete the environmental investigations and cleanup activities and transfer or lease the garrison property as soon as possible. The Financial and Accounting Center was transferred to the U. S. Department of Administration.
B. Environmental Issues
There were several restoration-related compliance activities conducted at the installation. All electrical transformers containing PCBs in concentrations greater than 50 ppm were removed by January 1990, and twenty-four of the 36 Underground Storage Tanks (USTs) at FBH were removed. Reconciliation of Army records and IDEM records are nearly complete.
Solid waste management units (SWMUs) and areas requiring environmental evaluation (AREEs) at FBH were identified in 1991 RCRA Facility Assessment (RFA) and a 1992 Enhanced Preliminary Assessment (ENPA) report. Thirty-six AREEs/SWMUs were identified in these investigations, and an additional two SWMUs were identified in later investigations. Originally the RCRA Facility Investigation and the Environmental Investigation were combined into one report. There were twenty two RFI sites and nine EI sites in the 12/92 and 4/93 reports. It was determined that there should be two separate documents.
U.S. EPA directed the Army to shift some of the sites out of the RFI and into the EI. Eighteen of the RFI sites were moved into the 7/94 EI document and one EI site was moved into the 7/94 RFI Report. The 7/95 EI listed 29 sites and the RFI lists seven sites (one is being investigated under the EI and the other is the West Landfill being investigated under the State Office of Solid and Hazardous Waste). The Phase I RCRA Facility Investigation (RFI) and the Phase I Environmental Investigation (EI) was scheduled to be completed in October 1994, but due to unresolved issues the schedule was delayed.
One of the major issues in the Environmental Investigation was the data validation. The State and U.S. EPA requested all the validated data on Ft. Benjamin Harrison for review. The validity of the data was questioned because of t he hybrid QAPP that was used. The QAPP was developed in December 1993 (using RCRA, CERCLA and Army methods) and it was used for both the RCRA Facility Investigation and the Environmental Investigation. Since the RCRA, CERCLA, and the Army programs have different requirements and the sites have switched from the RCRA program to the CERCLA program, it was difficult to satisfy all necessary requirements.
Other issues that needed to be resolved were
- unacceptable background sample locations
- the agencies did not approve of the statistic method/assumptions that the Army used to determining background concentration level
- the agencies did not agree with some the recommendation of no further action sites, since no samples were collected
- the agencies did not agree with the screening risks that were completed to eliminate sites from further action
- risk assessment issues (unacceptable statistical analysis used in determining background, background sample data locations and quality, and inconsistencies between chapters in the information in the Phase I EI).
Each program has different requirements and having a QAPP that used three types of procedures created a great deal of confusion. Due to all the problems encountered in using the December 1993 QAPP for both the Phase I EI and Phase I RFI, the Agencies (IDEM, U.S. EPA RCRA, U.S. EPA CERCLA, and the Army) reached an agreement in May 1995 to adopt a new QAPP for Phase II RFI and EI. The QAPP will follow the U.S. EPA Region V CERCLA Model QAPP. Ground water and surface water quantitation/detection limits must be low enough to be at or below the Maximum Contaminate Levels or other regulatory action levels.
1) RCRA Facility Investigation:
- The Final Phase I RCRA Facility Investigation Report was completed in April 1995. The Draft Technical Sampling Plan for Phase II RFI, the Draft Site Safety and Health Plan, and the Draft Quality Assurance Project Plan, Phase II RFI were received for review on April 28, 1995. The Draft QAPP, April 1995, was based on the December 1993 QAPP. This document was not review based on the May 1995 agreement to use the U.S. EPA Region V Model QAPP to develop the RFI QAPP. The revised Draft Quality Assurance Project Plan for Phase II RFI was received June 19, 1995. Resolution was finally reached on most of the issues that involved both the RFI and the EI investigations by October 1995. IDEM's comments on the RFI QAPP were distributed on October 24, 1995. The Army prepared a response package to agency comments on November 28, 1995. The RFI Workplan meeting, to discuss agency comments and the Army's responses on the Technical Sampling Plan and QAPP, was held on December 12, 1995 in Chicago. The Army did not address all the agency comments in the November 28, 1995 document. Several changes were needed so the Army prepared a revised response package to agency comments on January 23, 1996. IDEM reviewed and commented on the January 23, 1996 Army Responses on March 15, 1996. There were several issues that the Army had not addressed adequately.
2) Environment Investigation:
- The Army requested approval to collect background samples during the Phase II RFI instead on during the Phase II EI. Since both documents require the use of background sample data, collecting the background samples during the RFI would reduce time delays of waiting for the completed EI field work. The Army and IDEM/U.S. EPA were in disagreement regarding background sample locations. New information regarding SWMU #8 was presented to the agencies in two volumes of a Construction Clearance Study for the Learning Resource Center. The Construction Clearance Study indicated contamination at a depth of 25 feet at SWMU #8. Resolution of issues regarding the RCRA Facility Investigation were finally reached on April 4, 1996. The Final Technical Sampling Plan and the Final Quality Assurance Project Plan were issued in May 16, 1996. IDEM staff reviewed the final documents and sent a letter, dated June 16, 1996, concurring with the Final Technical Sampling Plan and the Final Quality Assurance Project Plan for the RCRA Facility Investigation for Ft. Benjamin Harrison. The RFI field work began June 27, 1996.
- The agencies could not come to a consensus on acceptance of the background sample locations and the statistic method/assumptions that were used in the Phase I EI to calculate the background concentrations, so IDEM proposed background concentrations that could be used to finalize the Phase I Environmental Investigation. IDEM selected a subset of the original background samples locations. A table listing the concentration ranges per media per analyte were developed. The upper number of the range was used per media per analyte to develop the background concentrations that were used in the Revised Final EI Report. The Revised Final Environmental Investigation Phase I Report was received September 20, 1995. This document has not received a formal review yet. The Army's contract expired and no revisions could be made to this document. The BCT agreed to move forward and focus on the Phase II EI Workplans.
3) Expedited Environmental Investigation:
- The scoping meeting for the Phase II Environmental Investigation Workplan was held in Chicago during February 1995. Resolution was finally reached on most of the issues that involved both the RFI and the EI investigations by October 1995. A meeting was held October 17-19, 1995 to discuss the Phase II Environmental Investigation sample location and the and the analytes to be sampled. During the meeting the Army presented their new proposed background sample locations. The Agencies were told during the meeting that the Army would have to have agency comments within two days (one of which was at the meeting) for our comments to be incorporated into the workplan. The Draft Phase II Environmental Investigation Document was received November 22, 1995. Agency comments were distributed on April 17, 1996. The Army responded to the agencies comments in a response package, dated May 20, 1996. The agencies received a document, dated June 21, 1996 that incorporated revisions to the lead sites and added new Environmental Investigation sites. A major problem that slows this process down is that new information is continually being found and is added piecemeal to study. The agency comments on the documents listed above should be completed in early August.
- Three sites: 1) EI SM25b, 2) EI SM25c, and 3) EI SM25l, have been removed from the comprehensive Environmental Investigation and were placed on a fast(er) track for investigation/remediation. These three sites are located on the FBH golf course.
4) Transfer and Lease Documents:
- IDEM and U.S. EPA gave verbal approval on the Work Plan for sites SM25b and SM25c provided the field copy of the Work Plan incorporated all changes as discussed in conference calls on May 15 and 16, 1995. Verbal approval was given on the Workplan on May 16, 1995. Field work was conducted on May 17 (mobilized), 18, 22, and 23, 1995. The Draft Report for Phase II EI of Sites SM25b and SM25c was received July 17, 1995. Several issues arose due to proposed construction in the area. IDEM staff comments were submitted to the Army on November 30, 1995. A meeting convened on January 23, 1996 to discuss agency comments. IDEM staff did not agree with the conclusion of the July 17, 1995 document. IDEM staff requested that the Army collect two additional samples to characterize the ash material at SM25c. Based on the new sample information and agency comments the Phase II EI for Sites SM25b and SM25c will need to be revised. The two ash samples were collected April 25,1996. The validated results should be completed in July1996. The Environmental Investigation can be completed. As an interim measure, the Department of Natural Resources was allowed to cover sites SM25b and 25c with a two foot soil cap. This would allow them to continue construction of the golf course.
- Site SM25l was originally identified as a former Grenade Range. The Army Corps of Engineers developed a workplan for locating and removing ordnance and explosives if found. In July 1995, the Army began conducting an ordnance and explosives Archive Search Report of files across the nation to determine if there was any potential for ordnance or explosives to exist anywhere else on the base. This Archive Search is required by the Army's Safety Board. IDEM had approved the draft Scope of Work for the Ordnance and Explosive work at site SM25l. The Army was in the process of developing a chemical sampling plan (for metals and explosives), when the results of the draft Archive Search Report identified that site 25l was a Grenade Court instead of a Grenade Range. This meant, since it was a court, that no live grenades were ever used in this area by the Army's definition. IDEM staff reviewed the section, pertaining to site SM25l, in the Draft Archive Search Report and determined that the State would not require any further action on site SM25l.
- IDEM staff reviewed and provided comments on May 24, 1995 on the Finding of Suitability to Transfer the FBH Golf Course to the State of Indiana. IDEM staff concerns were addressed either in the FOST, Environmental Baseline Survey, or our comments. The original transfer date was June 1, 1995. The U.S. Army signed the Finding of Suitability to Transfer the FBH Golf Course to the State of Indiana on June 2, 1995.
- IDEM staff reviewed and provided comments on the Findings of Suitability to Transfer the FBH Water Supply System to the City of Lawrence. The U.S. Army signed the FOST on July 7, 1995. The transfer was expected to occur during August 1995.
- IDEM staff reviewed and provided written and verbal comments on the Finding of Suitability to Transfer seven acres of land, building and parking lot parcels to the Reuse Authority. IDEM staff concerns were addressed in the EBS.
- IDEM staff reviewed and provided verbal and written comments on the Finding of Suitability to Transfer a Barracks Parcel and the Finding of Suitability to Transfer Harrison Village.
- IDEM staff reviewed and provided comments on the Finding of Suitability to Lease the State Park Parcel.
- IDEM staff reviewed and provided comments (through meetings with the Base Environmental Coordinator) by marking up copies of the Finding of Suitability to Lease, Economic Development Parcel, dated April 11, 1996.
- IDEM staff reviewed and provided comments (during meetings with the Base Environmental Coordinator) by marking up copies of the Finding of Suitability to Transfer, Economic Development Parcel, dated May 21, 1996.
- IDEM staff reviewed and provided comments (during meetings with the Base Environmental Coordinator) by marking up copies of the Finding of Suitability to Lease, Economic Development Parcel, dated May 1996.
- IDEM staff reviewed and provided comments (during meetings with the Base Environmental Coordinator) by marking up copies of the Finding of Suitability to Lease and the Environmental Baseline Survey for Buildings 40, 51, 428.613. and 615, dated April 23, 1996. A second revision was received later that same day.
- IDEM staff reviewed and provided comments (during meetings with the Base Environmental Coordinator) by marking up copies of the Finding of Suitability to Lease and the Environmental Baseline Survey for an Economic Development parcel, dated June 14, 1996.
C. Site Status
Issues have been resolved regarding the RFI Phase II Workplans. The Final Workplans were received on May 16, 1996. Concurrence was given to the Army on June 14, 1996. Field work began June 27, 1996.
IDEM staff comments on the Draft Environmental Investigation Phase II Workplans were distributed on April 17, 1996. The Army's response to comments was received May 21, 1996. A revision document to the EI Technical Sampling Plan was distributed June 21, 1996. The workplan should be completed September. Field work is anticipated to begin in September.
Agency comments were distributed November 30, 1995 on the expedited EI Phase II for sites SM25b and SM25c. The Army's response, to agency comments, was received on January 22, 1996, one day before a meeting to discuss the Army's responses. A meeting was held January 23, 1996 to discuss the Army's responses. Many of the responses dealt with risk assessment issues. A conference call was held on February 8, 1996 to discuss risk assessment issues. The Army collected two ash samples on April 25, 1996. The revised report is anticipated in late summer.
The Army is in the process of finalizing the Archive Search Report. Several areas at Ft. Benjamin Harrison will have to be swept for unexploded ordnance.
The Army's Report for the decontamination and demolition of buildings 605 and 27 is currently under review.
The Army's draft report, conducted by the Waterways Experimental Station, regarding the lead contamination on the firing range sites, will be distributed in July 1996. The Army has a draft proposed preliminary remediation goal of 500 ppm. Recent discussions with the Army show they may change the PRG to 800 ppm.