J u n e 5, 1989

M r . S t e v e n L .U S E P A , R e g i o n726 M i n n e s o t aK a n s a s C i t y ,

JonesV I IAve .

KS 66101

CHEMICAL RECOVERYCORPORATION

P.O. Box 79536402 Stadium Drive

Kansas City, Missouri 64129816/921-82111816/358-11311

< V

S00078000SUPERFUND RECORDS

Re.: Submission of RAW for Chemical Commodities, Inc.

Dear Sir :

Attached is the Removal/Remedial Action Workplan for the Chem-ical Commodities, Inc. Olathe facility.

The workplan proposes two components which may be somewhat un-familiar to EPA in this Region. The first of these is the usefor organic vapor screening, of a MIRAN I infrared spectrophoto-meter. This unit is a direct analog reading instrument capableof ppm level detection of most organic gases or vapors. Aswe put this unit to work, we would be happy to have anyone whowishes to observe be there to do so. The other method is theanaerobic microbial digestion of the contaminating chlorosolv-ents in the soil. This methodology is now a rather commonlyapplied procedure on the West coast and other industrial areas.We will be relying on that experience for guidance here.

We have made some alterations in the project schedule suggestedby EPA. We would request that EPA regard the schedule as ap-proximate only. Much of our schedule will be aimed at gettingthe bioremediation started as soon as possible, as experienceindicates a need of at least 8 weeks for sustantial degradationof contaminants by the microbes. We think it very likely thatwe will be at work until October to allow maximum remediation.Other tasks must precede this and some can run concurrently.

We are also aware that a couple of factory-only repairs mustbe made to our equipment before we can be fully at work. Thesewould not be made at this time unless EPA approves of this plan.With that in mind, we would ask that the schedule clock notbe started until about 15 days after approval. We anticipatethe need to consult with you on several details concerning theproject and look forward to the interaction.

The CCI project might be as near perfect for a bioremediationas can be found in the Midwest. We look forward with some excit-ment to a successful outcome.

Sincerely,

Merrill E. Nissen, D ir

RECEIVED

JUN 06 1969REM£ SECTION

Chemical R e c o v e r y Corlpd.ustrial and Hazardous Waste Reclamation

Removal Action Workplan

Chemical Commodities, Inc., Olathe Facility

Sampling and Monitoring Plan(SMP)

This plan encompasses the five or six areas of concern at thissite. These will be seen throughout this removal action work-plan. They are: 1) above ground storage tanks, 2) unknown pack-aged materials, 3) initial soil contamination survey, 4) soilremediation process, 5) site structure contamination and 6)off-site structure contamination.

SMP 1) Above Ground Storage Tanks

a. The four tanks south of Bldg. W are the focus of this work.These tanks are equipped with manholes and vents on top andscrew valves at the bottom. Initial sampling will be conductedfor vapors by inserting the pump probe of the MIRAN I infraredspectrometer through the manhole opening. The unit itself staysoutside the tank, hence there is no danger of ignition of tankvapors. The MIRAN I is a portable infrared spectrophotometercapable of monitoring many gases and vapors. It is equippedwith a cell having a 20 meter lightpath and thus is capableof measuring gases down into the 10 ppb range. The unit iscalibrated by first injecting an appropriate known volume ofthe subject solvent into a gas bulb of known volume, then with-drawing a known volume of gas or vapor with a gas syringe andinjecting that into the 20 m cell. The instrument is manufac-tured by Wilkes(now Foxboro). A set of well worked out analy-ical wavelengths and detection limits is provided by Wilkes/Fox-boro for many gases including all those which will become targetsubstances as a result of the findings of the initial site in-vestigation work commissioned by EPA. This unit has been apart of AZTEC Laboratories(the analytical division of ChemicalRecovery Corp.) analytical capability since 1976 and has servedwell. The instument is direct reading and can rather quicklytell what vapors are present and at what levels. It is an excel-lent process monitoTing device, and will be particularly usefulduring tank purging.

b. Tank contents and residues which are drummed will be charact-erized for proper manifesting.

SMP 2) Unknown Packaged Materials

One of the most important components of this task will be tocarefully and permanently mark each package and its correspond-ing sample and make records in the sampling logbook and journal.Even though the same individual may do the sampling and do oroversee the analysis, chain-of-custody documentation will beused for the transfer to the lab. Many of the unknown materialsboth solid and liquid, can be analyzed by infrared spectrophoto-metry. KBR pellet infrared is a technique typically used forsolids and liquid IR is straightforward. We do not expect toencounter unknown gases and we do expect one package to containone substance. If necessary, atomic absorption spectrometry

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for metals, ion specific electrometry for anions and gas chrom-atography or mass spectrometry tools can be brought to bear.In the event of emissions from the movement of containers, TheMIRAN I could be used for identification. Air sampling by per-sonnel sampler equipped with carbon tube, impinger or filterwith follow-up analysis in the lab could be used.SMP 3) Initial Soil Contamination Survey

Soil sampling on a 50 foot grid pattern is to be run over theentire site as defined by the site investigation soil gas sur-vey. Sampling is to be done by boring into the unsaturatedzone. In those areas where significant contamination is found,the grid pattern is to be reduced to 25 feet and determine thelateral extent of contamination. Numbered stakes will be drivenat sample points. Soil boring ssamples will be placed in samplecontainers of glass with septum caps which will allow for head-space gases to be withdrawn without opening the sample contain-er. Analysis will be by electron capture gas chromatographyin the laboratory. Chain-of-custody documentation with carefuljournalling will be used to maintain sample correlation withsampling point. In contamination areas, soil aliquots fromseveral depths will be used to gather information on plume sizeand shape. Special attention will be given to surface drainageways from the facility.

At E.4.d., the Order calls for installation of a minimum oftwo shallow ground water monitoring(GWM) we^ls and two deepwe^ls in contaminated areas. We wish to pospone that work toa later phase partly to see if it is necessary and if it isto place them to best advantage. In the response action plan,we propose to manage the leachate plumes discovered by excava-tion of the plume and bioremediation on the surface. If thatwork is successfully accomplished, the need for wells may change.Surface water and sediment samples will be taken from the NEcorner pit and the Shed F pit. Along with samples from theseveral GWM wells, these will be analyzed by EPA Method 601.Sampling from the GWM wells will be done by teflon bailer.We intend to take samples at the time of initial bailing ofwells, then after well recovery, take another sample to seeif there is any evidence of diminution. This may give an earlyindication of extent of contamination in the ground water.Bailed water will be stored for treatment in the irrigationphase of soil remediation.

In areas of known contamination such as between Shed F and westproperty line, east perimeter, NE pit, spill area between ShedF and Bldg. W and the above ground storage tank area, the sampl-ing will endeavor to map the leachate plume both laterally andvertically.

SMP 4) Soil Remediation Monitoring

a. With the best information derivable from initial soil borings,we will excavate from the center of a plume outward. We believethat the MIRAN I unit can be used to monitor soil gases aftereach shovel-full taken by the backhoe. At the point where the

Page 3

MIRAN I cannot adequately sense soil gases, a soil sample willbe collected in a sample container for transport to the labunder chain-of-custody documentation for analysis by gas chroma-tography. Adjacent excavation may proceed.If excessive soil gas is found at the lab, another bucket layercan be excavted the following day. In fairly short order, wewill learn which contaminating solvent has the greater mobilityin this soil and it can be used as an indicator.b. as the soil bioremediation proceeds, soil gases will be moni-tored there as well, either by MIRAN I, if effective, or bysoil sampling and GC analysis in the lab.

SMP 5) Site Structure Contamination

This task is distinct from the sampling and analysis of unknownpackaged materials and follows the removal of all materialseither by sale as product or removal and disposal as waste.It is assumed at that point that a covering of dust on floorswill be the primary source of remaining contamination. Samplesof floor residues will be taken for identification. It is like-ly that discreet areas will be contaminated with only one ortwo substances. We wish to clean such discreet areas one ata time. This will allow for segregation of incompatibles.It is anticipated that clean-up can be done by vacuum cleaner.As the gross clean-up is completed, a fine clean-up will followprobably with water and mop or sponge. Mild acidic, mild alka-line or detergent cleaning aids may be used as appropriate.Disposal decisions for the residues which are taken up willbe made when the nature of the residues is known. These deci-sions will be made in consultation with regulatory authorities.When the fine cleaning is done, a swab sampling will be doneto verify that final clean-up criteria have been met. Particu-lar attention will be paid to floor cracks and seams. It maybe necessary to repeat cleaning steps in some areas. Carefuljournalling of sample locations will be done to facilitate finalverification.

SMP 6) Off-Site Structure Contamination

It is possible that the MIRAN I unit will be found suitablefor screening nearby commercial and residential structures.It is anticipated that contaminants which might be found wouldbe limited to vapors from solvents known to be contaminatingsite soil and groundwater. In the event that vapors are foundwith the MIRAN I or that the detection limit with that instru-ment does not meet public health requirements for any of thepossible contaminants, personnel samplers can be set up at thelocation and gather sample by carbon adsorption for lab analy-sis by GC. Careful journal entry of sampling site and dataand chain-of-custody documentation will be used.

Pnge 4

RAW-Chemical Commodities, Inc.

Remedial Action Plan(RAP)

The Olathe site is a relatively small and simple site. Manyof the removal tasks can be handled in a straightforward manner.The single most significant remediation task will be that ofthe soil(including groundwater).

Several options appear to be available to solve the soil contami-nation problem, however, removal and land disposal is not oneof them since this would only move the problem, not solve itand land-ban regulations may be violated. One option wouldbe to remove the contaminated soil by drum quantity and haveit incinerated. This option might be practical if the amountof contaminated soil was very small, but that is not believedto be the case, based on initial site investigation data. Analternative option would be to bring in a mobile incinerator,but neither incinerator option is expected to be cost effectiverelative to others. A third option would be to sink severalmore monitoring and pumping wells and attempt to pressure flushthe contamination out with water. A fourth alternative wouldbe to do the same well installation but pressure inject anaerob-ic bacteria and nutrients to bioremediate the soil in-situ.The fifth option would be to excavate each leachate plume andmove it to a liner basin set up on the surface in the open spaceof the northwest corner of the site. It is possible that thethird or fourth options might be of lower initial cost but ef-fectiveness cannot be assured and long-term monitoring and re-treatment costs could easily make them much more expensive.We have recommended the last option to respondents and willbase the response plan for soil and ground water on option five.Other portions of the plan will deal with above ground tankremoval and removal of hazardous substances from structures.

RAP 1) On-site Soil Remediation

One of the most rapHdly developing hazardous waste managementtools today is that of biological treatment. A list of organicsustances found to be contaminating this site is found in Table1. All of the compounds are known to be degraded by soil mic-robes. At this time, the most proven pathway for the majorityof this group of compounds is anaerobic digestion and it isalso true that the best degradation may be possible for somecompounds only with genetically altered microorganisms. Thereare now several companies preparing and selling just such cul-tures for this use. A primary example is Polybac Corp. of NewYork. It is our intent to cooperate with them as a supplierof microorganisms and appropriate nutrient information to carryout this task. The time we have been associated with this pro-ject has been too brief to be able to name each organism tobe used and what effect it is expected to have but this canbe done before that phase of the work is reached.

The details of the plan are as follows:The initial site investigation soil gas survey concluded thatthe soil underlying the site was clay to a depth of at least8 feet and that contamination was of the spill type with plumesbeing well defined and having sharp edges. It is known that

Page 5

solvents do not move rapidly through clay soils, primarily be-cause water does not and water is the common mobile phase.Plumes are expected to be compact and well defined. We willassume, pending the outcome of initial soil sampling, that 60-70 cubic yards of soil will need remediation. This will requirea space of somewhat less than 45 feet by 100 feet, with theremediation layer up to 1 foot thick. A liner of that sizewill be acquired from Gundle at the proper time. The linerwill be 60 mil HDPE. The liner will be spread out in the openarea in the NW corner of the site and approximately 1 foot ofclean soil will be placed on the liner with enough liner exposedto drape completely over an oval of haybales. A portion ofmicroorganism/nutrient culture will be tilled into that soil.The objective here is to have anaerobes present in the layerbelow the contaminated soil layer so that contaminants leachingdownward during the digestion period will also be in contactwith degradative organisms. Then soil from the contaminatedareas will be placed and levelled to about 1 foot thicknesson top of that and anaerobes with nutrient will be mixed inby tilling. In fact, some naturally occurring aerobic organismswill be tilled in with the anaerobes so that oxygen incorporatedby tillage will be rapidly exhausted and allow the anaerobesto start their work. The soil bed will then be irrigated withcontaminated groundwater. The entire bed will be covered withpolyethylene sheet to prevent entry of air and exit of solventvapors. From that point, samples may be withdrawn weekly tomonitor the degradation of halosolvents. An interesting plusto this methodology is that as remediated soil is replaced inthe original excavations, the anaerobes will go with it andif unnoticed pockets of contaminant remain, the anaerobes willbe present and in the proper environment to degrade such resi-dues .

RAP 2) Residue Removal from Structures

It is anticipated that during the summer months while soil isbeing excavated and remediated, respondents will be arrangingfor sale(with consultation by regulatory personnel) or disposalof materials now stored at Olathe. As that material moves out,the way will be cleared to make the final samplings for analysisand clean-up of lingering residues. Those residues which arehazardous can be subjected to fixation and landfilled. Thosethat are not can go directly to sanitary landfill. We do notexpect the volume of these materials to be large.

RAP 3) Above Ground Tank Decontamination

This tak will be done first in order to clear this area forsampling and possible excavation of contaminated soil. Contentsof tanks have been moved to drums and are in readiness for dis-posal. Onapproval of this RAW, work can begin to decontaminatethe tanks. The first step will be to purge them of vapors.Depending on results of vapor analysis, each tank will be purgedfrom the top or bottom. Entry of air at the top will push

Page 6vapors heavier than air out through the bottom valve while

entry of air through the bottom valve will push lighter-thanair vapors out the top vent. The exiting vapors will passthrough activated carbon filters for adsorption. Filters willbe sent for incineration. Following displacement of vaporsentry by two-man teams will be made via the top manholes. Theteams will be equipped as set out in the HSP portion of thisRAW and will scoop or shovel, with non-sparking tools, the bot-tom sediment into buckets which will be pulled out on ropesand emptied into open head drums and readied for disposal.When the bases are clean, the walls can be rinsed down by pres-sure sprayer from the outside and top of the tank with the rins-ings being drawn off the bottom valve and placed in drums fordisposal. A first rinse with toluene or diesel will be followedby a rinse with acetone or isoprpanol. The final rinse willbe with water. This rinse will be retained for use in the irri-gation phase of soil remediation. At this point the tanks areready for removal as scrap.

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RAW-Chemical Commodities, Inc.

Health and Safety Plan

The primary objectives for this site are to decontaminate build-ings, storage areas and soil to safe levels. To do this, weexpect to carry out each step with sufficient deliberation sothat it can be accomplished with adequate safety, with efficiencyand with conservation of resources.

Work by respondent personnel has been in progress and will con-tinue in segregating known compatible materials into groups.This is important in generating financial resources as wellas clearing the way for decontamination of storage areas andallowing soil remediation to be done. We believe adequate work-er safety is insured for respondent personnel so long as theycontinue the segregation effort and don't become involved indecontamination or sampling of unknowns. In the early stagesof work respondent's time will be spent in assisting with pro-duct identification and the sale of product materials. Respond-ent personnel may also be involved in later stages of work inwhich decontamination will be involved but additional trainingwill be necessary prior to that time.

Areas where outside specialists and consultants will be respons-ible aretl) above ground storage tank decontamination, 2) sampl-ing both for soil contaminant location and building contamination3) soil remediation, 4) structure decontamination and 5) off-site structure sampling. The HSP is somewhat different foreach category, hence planning for each category will be separ-ate. In all cases, the key personnel involved will be MerrillE. Nissen for Chemical Recovery Corp.(CRC) and Jerald Gershonfor Chemical Commodities, Inc.(CCI). Actions are to be directedonly after consultation between these two key persons. WayneR. LaMere of CRC may function from time-to-time as an on-scenedirector or as field team leader. These persons will also func-tion as site safety officers.

HSP 1) Above Ground Storage Tanks

a. Possible risksTanks may have contained chlorinated solvents(heavier-than-airvapors) or flammable solvents such as gasahol(lighter-than-airvapors).b. Initial purgingVapor analysis will be done at the outset so the work environ-ment will be known. Vapors will be exhausted through carbonfilters for adsorption. In the case of heavy vapors, they willbe drawn off the bottom with fresh air entering at the top.Light vapors will be drawn off the top with fresh air enteringat the bottom,c. TrainingWorkmen will be used who have received training in respiratorfit and use, capabilities and limits of use for personal protect-ive equipment(PPE) , nature of the hazard in each tank, the humanfactor-heat exhastion, emergency procedures and self rescueand the use of the buddy system.

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d. PPEA decision will be made as analysis and purging are completedas to what gear will be needed, but level C is anticipated.Since this work will be undertaken in the warmest time of theyear, we may elect to do tank sediment removal very early inthe morning during cooler temperatures,e. Containment of residuesEach tank undoubtedly has bottom sediment which may be mostlyrust scale. These residues will be bucketed through the manholeon top of the tank and placed in open-head DOT approved drumsfor further testing and/or transport to landfill or incinera-tion .f. Tank decontaminationAfter sediment removal, the tanks will be ready for inner sur-face washdown. This will be accomplished with three rinseswith a pressure sprayer. The first will be diesel or toluene,the second isopropanol or acetone and the last water with deter-gent possibly. It is believed that a respirator equipped work-man can do the rinsing from outside the tank, on top, with thepressure sprayer equipped with two or three shapes and lengthsof wand. The solvent will be drawn off the bottom and placedinDOT drums for disposal at Interstate Environmental Services,6300 Stadium Dr., Kansas City, MO. The detergent water canbe reserved in plastic drums for use in the irrigation stepsof soil bioremediation.g. Decontamination of workmen and gearNo formal decontamination of workmen or their gear is anticipat-ed. Level C suits can be discarded and neoprene boots can bewiped and rinsed off with fresh tank wash solvents,h. Site ControlFurther site control measures for this task other than the exist-ing fence and closure of manholes at the end of work each dayis not anticipated.

HSP 2) Soil and Storage Space Sampling

a. Possible risksGeneral risks at this site are not believed to be high. Thereis some potential for toxics contamination, particularly inand near storage areas. There is some corrosives hazard butwith respondent personnel at hand, most of the unknown componentof the hazard will be removed. Floor contaminants in storageareas will be unknown and possibly toxics hazardous. Soil sampl-ing is expected to pose no significant hazard,b. TrainingOnly Mr. Nissen who has 15 years of sampling, analytical exper-ience and hazardous materials handling will be involved in stor-age area and container sampling,c. PPEHand, arm, facial and respiratory protection will be importantfor container sampling. Hand and possibly respiratory protec-tion will be adequate for storage area sampling.

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d. Soil samplingAuger borings will be used to gather most soil samples beforeexcavation starts. Sampling grid stakes will be used to marksample points. During this work, hardhat, toe and hand protec-tion will be appropriate. As excavation work proceeds, vaporsampling of freshly exposed soil will be done by portable infra-red analyzer but this work is expected to be done solely fromthe surface,e. DecontaminationSimple decontamination such as washing of hands will be suffic-ient.f. Site controlNo additional site control measures beyond what exist are expect-ed for sampling activites.g. Chain of custodyCareful logs will be maintained to track samples from theirsource through lab analysis. While Mr. Nissen will be involvedboth in sampling and analysis, chain of custody paperwork isexpected to be used to aid in sample tracking.

HSP 3) Soil Remediation

a. Possible risksHalocarbon solvents were the main contamination found in earlysite characterization. As excavation is carried on, any vaporsfrom these contaminants will lie in the bottom of the excavation.For that reason, all worker activity will be carried on fromthe surface. There will be a construction risk due to potentialsloughing of excavation walls. This can be controlled by slop-ing of the high clay soil,b. TrainingOther than equipment operation, there is little special trainingrequired in this task. Those who must work with the liner willbe given handling instructions so as to maintain liner integrity,c. PPESince contact with contaminants is not expected, no specialppe will be used. Hardhat wear will be required,d. DecontaminationThe decontamination need in this task will be applied to backhoedump truck and tiller and will be done after all excavationwork is complete,e. Site ControlDuring the time excavation pits remain open, they will be pro-tected by chain-link fence placed around each pit. The pitswill be left open to weather in the hope that hydraulic pressurefrom rainfall will force residual traces of contaminants toGWM wells where it can be withdrawn.

HSP 4) Structure contaminationa. Possible risksLittle risk is anticipated if the dust on floors is not disturb-ed as in sweeping,b. TrainingThe need for care in equipment operation and the minimizationof airborne dust will be emphasized.

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c. PPEWhile it is anticipated that dust respirators and gloves maybe required, it is also possible that no PPE will be required.The major clean-up task can be done with vacuum cleaner so longas dust is not lofted. Mopping will follow and both methodscan be done without body contact.d. DecontaminationRinsing of equipment can be done with water. If contaminantsare biodegradable(heavy metals excluded), the rinse would beuseable in the bioremediation task.e. Site controlNo special measure anticipated.

HSP 5) Off-site Structure sampling

a. Possible risksNo special risks would seem to be posed other than normal house-hold risks,b. TrainingVery special training in public relations may be needed to handlethis taskc. PPENone is anticipated. The presence of such equipment would beunnecessarily alarming,d. DecontaminationNone anticipated,e. Site ControlNone anticipated.

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RAW- Chemical Commodities, Inc.

Risk Assessment and Clean-up Criteria Plan(RACC)

RACC 1) Solvent Contamination

Two risk vectors from solvent contamination can be identifiedfor the Olathe site which in the final analysis devolve to onevector. The first of the two risks is possible contaminationof confined air spaces of residential and commercial structureson or near the site. The means by which such space could havebecome contaminated is the migration of vapors or liquids throughthe soil or ground water and vaporization into confined space.At this point, we do not know if we have an actual contaminationin such air spaces. The preliminary IR screening will be indic-ative. If there are indications, we plan to immediately placesome permissible air samplers to make an exact determinationby means of Tenax adsorption tubes. If there are no indicationsof contamination in such confined spaces, the remaining vector,and really the root of both, is left for removal by soil remed-iation .

Initial site investigation data is bought together in Table1. Permissible levels of the target substances and a cancerrisk factor are summarized in Table 2. The risk factor forcancer is for injestion of chronically contaminated water atthe level shown. At this writing, airborne contaminant levelsas cancer risks are not at hand. The ground water is not thesource of drinking water for nearby residents and since therisk data applies to drinking water supplies, the implicationsfrom the data are limited.

Data from Tables 1 and 2 may be used to do some rough extrapo-lations of risk. Note that the ground water findings fromTable 1 are all below the permissible level except for tetra-chloroethene and chlorobenzene. Soil gas findings are two ordersof magnitude less than permissible water levels and four ordersless than most permissible levels in air. This would suggestlittle risk from outgassing of soils.

A permissible level in air for tetrachloroethene is about 60fold what it is in water. Perhaps an acceptable risk air levelfor this solvent could be taken as 60 fold the water level of0.008 ppm( assuming a cancer incidence risk of 1 per 100,000is acceptable) or 0.45 ppm tetrachloroethene.

It is possible that tetrachloroethene could be used throughoutthis remediation as the indicator molecule. At 0.45 ppm, theMIRAN unit will be very adequate to tell if confined air spacecontamination is present. Furthermore, the observed level ofthis molecule is the highest in ground water samples. It couldbe used as an indicator of remediation success, either by moni-toring ground water levels for this indicator after excavationand/or by monitoring soil levels during bioremediation.

« » >Page 12

Table 1CLEAN-UP TARGET SUBSTANCE LIST

ForChemical Commodities, Inc., Olathe Facility

Substance

1.1-DichloroethaneChloroform1.2-Dichloroethane1,1,1-TrichloroethaneCarbon Tetrachloride1,2-DichloropropaneTrichloroethylene(TCE)Tetrachloroethene1,1,2,2-TetrachloroethaneChlorobenzene

Ground Soilwater GasFindings Findings

MIRAN IDetection

Limit, ppm

2.995 mg/1 ——13611

1113

,562,734,590,716,992,112,240

0.7201.761

Bis(2-ethylhexyl)phthalatel.500

0.30.1

—— 0.3—— 0.20.050 ,mg/l 0.08—— 0.80.027 0.20.008 0.080.0 1.4

0.4

Table 2

PERMISSIBLE LEVELS AND RISK FACTORS

Substance

1,1,DichloroethaneChloroform1,2-Dichloroethane1 ,1,1-TrichloroethaneCarbon tetrachloridje1,2-DichloropropaneTrichloroethylene(TCE)Tetrachloroethene1,1,2,2-TetrachloroethaneChlorobenzene

Permissible Level, ppm Cancer* .Water Air.TWA Air.STEL Rtek Aevel

28.9201835.223450.842.40.02

Bis(2-ethylhexyl)phthalate 15

200101035057550501755

250501545020110150Soo5none10

animalanimalnon-0.04 ppm0.0270.0080.0017

* Cancer incidence rate of 1/100,000 from injestion of chronicallycontaminated water at these levels in ppm

TWA=time weighted averageSTEL= short-term exposure level

*•

P«age 13 v̂ 'Y-

Without more and/or better data, a clean-up criterion may beimpossible to set. As goal setting aids the following criteriamay be considered:

Soils- other regions of the country use 100 ppm as themark of cleanliness.

Groundwater- reduction of indicator molecule tetrachloro-ethene to 0.84 ppm or less and other listed target sub-stances to permissible water levels.

Confined air spaces- reduction of indicator molecule tetra-chloroethene to 0.45 ppm or less.

RACC 2) Metals or Other Toxics Contamination

Contaminating toxics were not seen from early site investigationanalytical work to be especially significant. Suspect areaswill be examined closely as stored materials are removed.

For example, the "railroad buildings" are expected to be emptiedearly in the work. As they are, floor samples where spillshave occurred, and a representative number of points aroundthe floor and at the doorway will be taken and analyzed by TEP.The criterion for cleanliness must be that final samples showno hazardous characteristics. This process will be carriedout for each storage area.

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RAW- Chemical Commodities, Inc.

Quality Assurance Project Plan

This plan applies primarily to analytical work which will bediscussed in three segments.

QAPP 1) Vapor Analysis by MIRAN I

Calibration of the unit must be done whenever it is turned onor whenever the wavelength is changed. A zero analyte and twoconcentrations near the expected detection limit are used tocalibrate. This unit is not intended to be a highly preciseanalytical instrument such as a gas chromatogragh. However,it is possible to perform most of the quality assurance proced-ures usually applied to gas chromatograghy.

QAPP 2) Organics Analysis by Gas Chromatography

We will endeavor to acquire about 10 samples at a time for onekind of analysis. Much of the solvent gas chromatograghy willbe done by EPA Method 601.a. Precision determinations will be made by running duplicatesevery fifth sample. Accuracy will be determined by spikingduplicates with known concentrations of target compounds,b. After each ten samples, a standard mixture will be run.If the response or retention time differs by more than 10% fromthe standard run at the beginning of the sample set, standardswill be checked for deterioration and the instrument sensitivitywill be checked for losses. The previous sample set is to bereanalyzed .c. A blank run is made following the standard to check for shad-ows or carryover of analyte.d. Standard Verification is done for our standards which areobtained from Supelco. EPA performance evaluation samples fromprior studies or EPA QC samples are used for comparison. Stockstandards for volati.le organics are prepared every month andkept in the freezer. Work standards are prepared daily andcompared with those previously made for deviation,e. Spike recoveries are monitored as a method quality control.These are compared to known EPA QC limits.f. Replicates are tested by calculating the relative pecentdifference(RPD). The difference between duplicate determinationsis taken. That value is divided by 1/2 the sum of the two deter-minations and the result is converted to a percent. This RPDshould be ±30%. A result outside this range indicates matrixproblems, insufficient care in conducting the runs and a needto repeat the set. Known and unknown QC samples are run, usuallyfrom EPA performance evaluation studies.g. Soils are also spiked as field duplicates for headspace gases.One of a duplicate pair can be spiked through the septum,, thesample agitated for several minutes and the known spike comparedwith the remaining duplicate.

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QAPP 3) Records

A calibration log is maintained on insturraents used which recordsresults of calibration, comparisons to EPA standards, datesand types of work performed on the instrument and by whom.

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RAW-Chemical Commodities, Inc.

Contingency Plan(CP)

The hazardous materials being removed from this site will behandled in quantities not exceeding 55 gal. These materialswill consist of solvents, both flammable and chlorinated. Therewill also be mineral acids and alkalies as well as organic andinorganic compounds of various types. The cleaning and removalof four large empty tanks is also a part of the removal plan.The excavation and remediation of 60-70 cubic yards of contamin-ated soil will be accomplished on site.

This plan is designed to minimize hazards to human health andthe environment from fire, explosions or any unplanned suddenor non-sudden release of hazardous material to the air soilor surface water. This plan must be carried out immediatelyif a fire, explosion or spill occurs at the site.

CP 1) Information to Emergency Response Personnel

On approval of the RAW, the Olathe Fire Dept. and Olathe MedicalCenter at 215 W.151st St. will be notified of our activity,our expected schedule of work and given a copy of this plan.

CP 2) Emergency Equipment

Fire extinguisher, CO- type at least within 50 feet of tasksite.Adsorbent material(2 bags vermiculite).Sodium carbonate for neutralization of acid spills, 2 bags.Boric acid for neutralization of alkali spills, 1 bagShovel and bucket.Telephone, within 100 feet, on premises.Face masks/respirators.

CP 3) Emergency Equipment Capabilities

Adsorbent will pick up 4 times its weight of liquid. The tele-phone system will allow ready access to outside emergency re-sponse. If warranted, a cordless system could be used withthe handset at the task site. The respirators are Mine SafetyAppliance canister or catridge type. Canisters and cartridgeson hand are for organic vapors.

CP A) Evacuation Plan

If evacuation is necessary, all personnel will use emergencyexit doors(see map). The evacuation signal will be by voiceinstruction. The evacuation order will be made by the fieldteam leader and repeated three times.

CP 5) Evacuation Routes and Assembly Area

The attached site map shows evacuation routes and the assemblyarea in front(North) of the office.

17CP 6) Emergency Fire/ Explosion Procedure

The threat of fire or explosion is not seen to be high. Themost significant threat of this kind is with the large storagetanks. These tanks have been emptied. By following our planof purging and entry with no ignition source, we believe a safecleaning can be done. In the event of a fire at the large stor-age tanks, all personnel are to retreat to a safe distance,contact fire personnel and wait for assistance. In the eventof a small fire as from a spill, an attempt to contain the firewith extinguishers should be made. If the fire cannot be quick-ly controlled, all personnel should evacuate bu emergency routesand assemble at the front or north of the office.Cp 7) Spillsa. Warnings-

No flames, smoking or flaresin area.20 Stop leak if possible without risk.3) Use appropriate method for clean-up.

b. Small spills- Use adsorbent to pick up liquid. Dispose inopen head 17H drum.

c. Large spill-1) Contain if possible2) Stop leak if possible without risk.3) Us e adsorbent material and shovel into spill drum.4) Stop machinery/electrical ignition sources.5) Use portable pump to pump into spill drum.6) Clean spill area.

CP 8) Key personnelPrimary Emergency Coordinator

Merrill E. Nissen3931 Arlington

Kansas City, MO 64133(816) 921-3922(816) 921-8211(816) 358-1131

AlternateJerald Gershon

Chemical Commodities, Inc.320 S. Blake

Olathe, KS 66602(913) 782-3200(913) 341-0808

AlternateWayne R. LaMere

Chemical Recovery Corp.6402 Stadium Dr.

KAnsas City MO 64129(816) 921-3922(816) 921-8211(816) 254-8328

CP 9) Training- task specific, requirements, hazards expected.

Page 18

Organizational Structure

I-

I

r

"* 1

CHEMICAL COMMODITIES INCOlathe. Kansas

Febuary 1989 Sampling

'/'• p.paragraphNumber

E.4.a.

E.4.b.

E.4.C.

E.4.d.

E.4.e.

E.4.f.

E.4.g.

E.4.h.

E.4.I.

E.S.a.

E.5.b.

E.5.C.

E.S.d.

E.S.e.

E.S.f.

Action StartType Dav

Sample & Identify 0Containers

Ambient Air 0Monitoring

Boring Survey

GW Monitoring WellsInstallationSamplingSamplingSampling

Surface WaterSampling

Soil Sampling

Dwelling Sampling

Site BuildingSampling

Verification 10Sampling

Additional 15Segregation

EndDay

30

TBD

Comment

20

3575115

30

35

0

80

4080120

35

25

125

TBD

35

Drain, Empty 0 45and/or Decontaminate Equipment

RepackageContainers

Decontam inateBuildings

Soil Treatmentor Disposal

30

120

90

Ambient AirMonitoring shallcontinue as neededthroughout the project

Sampling shallcontinue on 40-dayintervals untilshallow GW cleanupcriteria are met.

Verification samplingshall be performed asneeded until cleanupcriteria are met*

Surface Water 120Collection It Treatment

7 K-̂ . ^ >

E.S.g. Ground Water 12O1 TBD The GW Removal andRemoval & Treatment Treatment System

shall continueoperation untilcleanup criteriaare met*

E.S.h. Haste Treatment 10 180or Disposal

1 In the event that dwelling air monitoring and/or the boringsurvey data indicate that contaminated shallow ground water is apresent threat to persons offsite, the installation andsubsequent operation of the ground water collection and treatmentsystem shall commence on day 25.