EPA Region 5 Records Ctr.

DuPont Engineering Barley Miii Pla^a Biclg. 2? 441;' ' Lancaste-!- Pike Wilmington, DE 1930G

WMi EPA Region 5 Records Ctr.

OtiFont Engineering 311867

October 18, 2004

Ms. Pamela Molitor, Remedial Project Manager Remedial Response Section 6 (SR-6J) United States Environmental Protection Agency, Region 5 77 West Jackson Blvd. Chicago, IL 60604

S U B J E C T : F I N A L R E V I S E D P R A O AND I C T T E C H N I C A L M E M O R A N D U M F O R T H E F O R M E R P E T E R S C A R T R I D G E C O M P A N Y S I T E ( C E R C L A D O C K E T N O . V-W-04-C-792)

Dear Ms. Molitor,

Please find enclosed one copy of the final revised text for the Preliminary Remedial Action Objectives (PRAO) and Identification of Candidate Technologies Technical Memorandum for the former Peters Cartridge site in Warren County, Ohio. As you requested, the document has been revised to include comments on page 14 regarding evaluation of ashlike fill materials in Area A and the fill materials in the former reservoir. The comments included reflect the agreements reached during our September 2 1 , 2004 conference call that were documented in the DuPont letter, dated September 27, 2004, submitted to U.S. EPA.

A copy of the enclosed text is also being submitted to Ohio EPA. If you have comments or questions regarding this submittal you may contact me at (302) 892-8035.

Sincerely,

(^Satnya V. Yalvigi, Project Director

cc: Terrence W. Stanuch, USEPA Jyl Lachapin, Ohio Environmental Protection Agency Nigel Goulding, URS Corporation BMP File

PRELIMINARY REMEDIAL ACTION OBJECTIVES (PRAO) AND IDENTIFICATION OF CANDIDATE TECHNOLOGIES (ICT) TECHNICAL MEMORANDUM FOR THE FORMER PETERS CARTRIDGE SITE

Date: October 5, 2004 Project No.: 18983865/502434

^

URS Diamond 5200 Blazer Parkway EH&S, DS-4 Dublin, OH 43017

PRAO and ICT I n t r o d u c t J o n

TABLE OF CONTENTS

1.0 Introduction 3 1.1 Site Location and Setting 3 1.2 Site Ownership 4 1.3 Vicinity Properties 5

2.0 Site Operational History 7 2.1 Site Geology and Hydrogeology 8 2.2 Surface Water and Municipal Supply Wells 9 2.3 Site Conditions 9

2.3.1 Soil 10 2.3.2 Groundwater and Surface Water 10 2.3.3 Culvert Samples II 2.3.4 Fish Tissue SUidy 11

2.4 Site Conditions Summary 11 2.5 Potential Exposure and Migration Pathways 12

3.0 Preliminary Remedial Action Objectives 14 3.1 PRAO Summary 17

4.0 Identification of Candidate Technologies 18 4.1 Soil 18 4.2 Groimdwater 19

5.0 References 20

TABLES

Table 1 History of Owners/Occupants Former Peters Cartridge Co. Site

Table 2 Former Peters Cartridge Facility Historic Site Buildings/Structtires

Table 3 Project Schedule for Major Deliverables

3865_PRAO_ICT_3.0 Dublin, OH

PRAO and ICT introductjon

FIGURES

Figure 1 Site Location Map

Figtire 2 Site Layout and Topography Map

Figure 3 Current Site Layout

Figure 4 Drainage Channel Map

Figure 5 1890's Site Layout

Figure 6 Peters Cartridge Facility-1925

Figure 7 KMOP Remington Plant

Figure 8 KMOP Government Plan

Figure 9 Historic Sampling Locations

Figtire 10 Ohio EPA Identified Areas of Impact

APPENDICES

Appendix A Historical Investigation Data


PRAO and ICT Introduction

1.0 INTRODUCTION

E.I. duPont de Nemours and Company, and Remington Arms Company, Inc., referred to herein as DuPont and Remington, respectively, have entered into an Administrative Order on Consent (AOC), effective July 14, 2004, with the U.S. Environmental Protection Agency (EPA) for a Remedial Investigation and Feasibility Study (RI/FS) at the former Peters Cartridge Facility in Warren County, Kings Mills, Ohio. The requirements for the RI/FS are described in the statement of work (SOW) in Appendix A of the AOC.

Pursuant to Task 1.2.2 in the SOW, this preliminary remedial action objectives (PRAOs) technical memorandum has been prepared. The PRAOs have been developed with consideration for the current site conditions as well as historic site data. Information related to site operations was obtained from public and private records including: site investigation reports, state and federal environmental databases, land and title records, aerial photographs, personal interviews with historians and persons associated with the site, and general industry knowledge of munitions manufacturing processes. A brief summary of the site history, previous investigation fmdings, and current site conditions is included herein and forms the basis for the PRAOs.

1.1 Site Location and Setting

The Peters Cartridge site is located along the southern bank of the Little Miami River (LMR), southeast of the city of Kings Mills, in Warren County, Ohio. A site location map is provided as Figure 1. The site occupies approximately 71 acres and is located primarily west of Grandin Road. Approximately 1 acre is located to the east of Grandin Road. An aerial photograph showing site and vicinity area features and topography is included as Figure 2.

For reference and discussion, the site is divided into Area A and Area B. Area A, which occupies approximately 15 acres, is located along the river and is relatively flat. The main facility buildings and the Little Miami Bike Trail are located in Area A. The groimd surface adjacent to the buildings, as well as the bike trail, is paved with asphalt/concrete. The remainder of the site, referred to as Area B, occupies approximately 56 acres and is characterized by steeply sloping bedrock ridges and dense vegetation. Numerous outbuildings, btxnkers, concrete supports, foundations, conveyors, and other facilities historically used by the Peters Cartridge Co. are located throughout Area B. The current site layout showing existing facilities is included as Figure 3.

The site is bordered to the north and west by the LMR (designated as a State and National Scenic River) to the southwest by a U.S. Army Reserve Center [formerly part of the Kings Mills Ordnance Plant (KMOP)] and the Warren County Water District water treatment plant and to the east and southeast by rural and tmdeveloped properties. The nearest residences are approximately one-quarter mile north of the site, on the other side of the LMR. State and federally listed endangered species have been foimd in and around the LMR, although none were observed near the site during previous site assessments


PRAO and ICT Introduction

[PRC Environmental Management, Inc. (PRC), 1994]. Approximately three miles of wetlands front the LMR within 15 miles downstream of the site (PRC, 1996).

The site topography ranges from approximately 620 feet to 730 feet above mean sea level (ft msl). Surface water across the site generally flows north through several ravines on the southern portion of the site. Three primary drainage flow areas cross the southern portion of the site, and direct overland water to three man-made culverts that run beneath the buildings on the northem portion of the site. Stormwater from the culverts ultimately discharges to the LMR. A drainage channel map is included as Figure 4.

The eastem-most ravine conveys surface water nmoff from properties located northeast of the site, across Grandin Road. The swale runs beneath Grandin Road and into the concrete culvert on-site that runs beneath building R-2. The central and western ravines convey surface water runoff from the site and adjacent properties to the south. The central and western ravines drain to two man-made culverts that run beneath buildings R-3 and R-9, respectively. Dry wells are located along the southem site border and on the adjacent water treatment plant property. The dry wells are used to manage surface water runoff from the water treatment plant site via infiltration. The locations of the dry wells are noted on Figure 4.

1.2 Site Ownership

The site was developed in 1887 and used for the manufacture of explosive ordnance and shot shell ammtmition by the Peters Cartridge Co. tmtil 1934. Around 1934, Remington Arms purchased Peters Cartridge Co. and continued the production of shot shell and cartridge ammunition at the facility. In 1941, Remington renovated the site and provided design assistance for the new KMOP to the U.S. Government imder a program known as the "Unit Plan". Under this plan, major arms and ammtmition manufacttirers would work with arsenals to develop, construct, equip, and operate ammtmition manufacturing plants. This system of conscripting private manufacturing's labor and expertise allowed the arsenals to quickly increase production when needed without having to fund a standing arsenal system in peacetime. Ordnance plants under the unit plan were referred to as GOCO plants-"Govemment Owned Contractor Operated" (Sharpe, 1947, as reprinted by Schiffer, 2002). The new government owned KMOP facility began production in 1942. Both facilities manufactured .45 caliber carbine ammunition for less than a year. Thereafter, Remington and KMOP manufactured .30 Caliber carbine ammunition tmtil 1944, when operations at both sites were discontinued.

Since 1944, the former Peters Cartridge site has been owned and occupied by various entities. A list of owners, tenants, and the dates dtiring which they occupied the site, is included as Table 1. Figure 3 depicts current site conditions, including which buildings are still standing, which buildings are occupied, and which structures have been demolished. From 1987 through 1991, LensCrafters conducted eyeglass frame manufacturing and optical lens coating operations in portions of buildings R-3 and R-9. Freon®-! 13 was used as part of these operations. A discharge of Freon-113 to the site's septic system, and subsequently to soil and groimdwater, was discovered in 1990. LensCrafters conducted a partial clean-up in 1993. There are no known or reported


PRAO and ICT Intfoductlon

releases associated with the other owners or tenants that have occupied the site since 1944.

Area A is owned by Kings Mills Commerce Park. A few small businesses currently occupy portions of two buildings. A metal machinist is located in R-3. An artist's studio (painting and sculpture, etc.) and a cabinet manufacturer are located in R-9. Area B is owned by Lewis Real Properties Co., LLC, and is currently vacant.

1.3 Vicinity Properties

Past operations in the immediate vicinity of the site include:

• Gunpowder manufacturing from 1878 to 1958 by Kings Powder Co. along the north bank of the LMR across from the site,

Q Munitions manufacturing at the KMOP government plant, located adjacent to the southem end of the site, and

Q Paint manufacturing operations by Diversified Products, Incorporated at the former KMOP government plant.

The former KMOP government plant site is listed in State and Federal environmental databases as a hazardous waste treatment, storage and disposal facility, and is designated as a high priority corrective action site.

Current operations in the immediate vicinity of the site include the Warren Coimty water treatment facility. The treatment facility was developed sometime after 1980. Dtiring construction and renovation, excavated soils from the water treatment facility were used to backfill a reservoir on the former Peters Cartridge site.

KMOP miuiitions operations at the government plant were similar to those conducted by Remington at the former Peters Cartridge Site. Additionally, lead styphnate primer, referred to as Polnol, was manufactured at this location, and a disposal system was utilized for Pohiol process water (DtiPont, undated). The Polnol disposal system was composed of vitrified sewer pipes that acted as a collecting sewer for fotir primer mixing buildings, a concrete sump pit 25 feet in diameter by 20 feet deep, and an outfall sewer constructed of transite pipe. All wastewater from the government plant was passed through the disposal system for chemical treatment to neutralize the Polnol. The wastewater was freated in three wood reinforced tanks contained within the sump pit. Wastewater was discharged into a swale south of the plant's manufacturing area. Sludge from the process was transferred to drying beds nearby. The Pohiol manufacturing facility's location is shown on the KMOP site layout figure in attached Appendix A.

The KMOP sewer system collection pipes and sump pit were installed below grade in areas where springs and a water bearing vein of gravel were encoimtered. Portions of the sump and piping were below the groimdwater table. At some point during operations, groundwater infiltration to the collection system was discovered. Infiltration was attributed to numerous breaks in the collection lines/pipe joints, where grout had been washed out. Following this discovery, all lines installed below the groimdwater table were excavated and reconnected using a more robust joint sealing compound (DuPont, imdated). Lead concentration data from previous groimdwater investigations on the


PRAO and ICT introduction

KMOP government plant site ranged from 14.8 micrograms per liter (|Jg/L) to 37 (ig/L (PRC, 1996).

Sometime after KMOP munitions operations ceased. Diversified Product Inc. conducted paint manufacturing operations at the former KMOP government plant. Chemicals associated with the paint manufacturing operations, including chlorinated hydrocarbons, have impacted soils and groundwater at the facility. The site is listed on state and federal environmental databases as a hazardous waste treatment, storage and disposal facility, and as a high priority corrective action site.

3865_PRAOJCT_3.0 Dublin, OH

PRAO and ICT Site Operational History

2.0 SITE OPERATIONAL HISTORY The Peters Cartridge facility was in operation for a period of approximately 50 years. The production of paper shot shell ammunition was the primary fiinction of the facility. Metal cartridge ammunition was also produced during brief periods, primarily to support military efforts during World War I and World War II. Site operations included primer mixing and wad production, cupping and drawing of shell heads and casing cartridges, and shell/cartridge packing and assembly. Metals likely used in the manufacturing process included lead and mercury for primer, and to a lesser extent, copper and possibly nickel (for plating casings).

Throughout the operation's history, facility renovations and new construction were conducted as needed. Based on historic data, the materials used and products produced in renovated or new structures were similar in nature to what was produced in the area previously. Moreover, the general areas where specific types of production activities occurred (i.e., primer mixing, lead shot production, packing, etc.) remained consistent over the operating life of the facility. Facility layouts for the Peters Cartridge Co. in 1890, 1925, and for the Remington Plant and KMOP government plant in 1942 are included as Figiu-es 5 through 8.

Site buildings and facility structures shown on the attached figures are identified using numbers and descriptions referenced in historic documents. Building identifiers beginning with "R" indicate structures that were part of the Remington Plant during the period of time that both Remington plant and the KMOP government plant were operational. Other names refer to historic fimctions/processes conducted at the location. A list of the structures known to have existed at the site, and available information related to construction and associated operations conducted at those locations, is included as Table 2.

The facility was served by the Little Miami Railroad tmtil sometime after 1922 (Schiffer, 2002). The former rail line included a rail siding that crossed through Area A between the main buildings and two rail spurs located near the river and adjacent to building R-21 at the northern comer of the site. Concrete supports for the elevated spur still exist, and are shown on Figure 3. All rail lines have been removed, and the rail right-of-way has been redeveloped as the Little Miami Bike Trail.

Historical data indicate that the main manufacturing processes were conducted in Area A. Those processes and building fimctions included shell assembly and inspection (R-I), packing house and lab (R-2),test center and firing range (R-23), shot tower (R-3 5), machine shop and metal stores (R-3), blacksmith shop (R-54), lead bullet house (R-6), and primer house (R-9). The building locations are depicted on Figure 7, and descriptions of the facilities are included in Table 2. Two other shooting galleries/ranges were historically located on-site. One was parallel to and east of Grandin Road near R-21 and the other was parallel to the river on the northwest portion of the site. These shooting ranges are shown on Figure 6.

Throughout Area A, elevated walkways connected the majority of the main buildings and were used for conveyance of raw materials, products and persoimel between buildings.

3865_PRAO_ICT_3.0 7 Dublin, OH


For example, production supplies were stored in R-21 and conveyed to R-2 via an overhead passageway, R-53. Salvage facilities were located on the northwestern comer of the site. R-l9 was the main power house, and contained engines and generators. Other facilities were adjoined to building R-l9, including water softening equipment (R-37), steam driven fire pumps (R-24) and coal conveyor equipment (R-39). A water treatment system and boilers were also located between buildings R-l and R-l9. The earliest boilers were originally located in Buildings R-35 and R-58. When the new boiler house, R-l9, was constmcted in 1917, these two buildings were subsequently used for the manufacture of clay targets. A 22-foot diameter concrete and brick building, R-36, located on the bank of the LMR, housed pumps and chlorinating equipment for treating water that the facility provided to the Village of Kings Mills. Employee faciUties were housed in buildings R-l (offices, medical facilities and cafeteria) and R-l6 (locker room).

Support facilities were constructed throughout Area B. They included:

i::! target ranges (Areas A and B),

Q storage bunkers and magazine houses,

• conveyors,

Cl a fire water reservoir (currently backfilled),

1̂ pump house and sluice gate (R-77) near the former reservoir on the central portion of the site,

• process control houses (R-71 and R-76),

• primer mixer houses (R-63 and R-72),

Remnants of walkways and water, steam, and electric pipe supports exist on site which historically ran between Areas A and B, and between the former Remington Plant and KMOP Government Plant sites.

2.1 Site Geology and Hydrogeology

Located in the Little Miami River basin, the former Peters Cartridge site is underlain by glacial till, gray shale and limestone bedrock. Surface soils consist of sandy and silty clays ranging in thickness from 20 feet to 35 feet. Historical data indicate that fill materials containing ash, brick and other debris, exist in layers ranging from 2 feet to 10 feet thick. Fill materials have been noted ia. Area A, particularly in the salvage area and southwest vicinity of Building R-1. The silty clay is underlain by a bed of sand, gravel and silt from 5 feet to 15 feet thick. Gray shale and thinly bedded limestone (bedrock) is present at depths ranging from 20 feet to 40 feet below ground surface (bgs). The bedrock beneath the site dips to the west.

Shallow groimdwater beneath the site generally flows to the northwest toward the river, following the slope of the bedrock beneath the site. Previous investigation data shows groimdwater in Area A at a depth of approximately 15 feet bgs (PRC, 1996). Surface and infiltration water flow toward the LMR.



2.2 Surface Water and Municipal Supply Wells

The site is located in a 100-year floodplain, approximately 250 feet south of the LMR. The LMR is an active sport fishery, and is designated as a State and National Scenic River. River flow is approximately 870 cubic feet per second, and the maximum, 2-year, 24-hour rainfall for the area is approximately three inches (EPA 1996).

A man-made water reservoir was located on the southem portion of the site for fire protection service. The reservoir was backfilled in 2001 as part of the Warren County Water District water treatment facility upgrade. The reservoir and treatment facility are noted on Figure 4.

As noted in Section 1.1, surface water on-site follows land surface topography and flows north, toward the river. Three main ravine-type swales convey surface water from the site dovra the sloping valley walls to storm sewers that run beneath the site buildings. Cement box culverts and undergrotmd piping convey storm water beneath the Little Miami Scenic Trail, and ultimately to the LMR. Surface water, from the Army Reserve Center and other neighboring sites to the east, south and west, flows into swales on the site. Two dry wells are located on-site adjacent to the water freatment plant. Additional dry wells and catch basins are present on the water treatment plant property. Surface water from the treatment plant site is conveyed to the dry wells and onto the former Peters Cartridge site via infiltration.

Fifteen Warren County municipal water supply wells are located within a 3-mile radius of the site. There are six wells at the Hamilton-Deerfield well field located approximately 0.3 miles west, three wells in the sod farm well field approximately 1.7 miles northeast, and six wells (three each for Lebanon and South Lebanon well fields) over 2 miles northeast. The Hamilton-Deerfield wells are screened in shale at depths ranging from 35 to 75 feet bgs, and pump about 2.75 millions gallons per day (gpd), supplying water to over 14,800 people. The South Lebanon wells are screened in the sand and gravel aquifer between 65 and 80 feet bgs, and pump about 0.45 million gpd. The South Lebanon wells serve approximately 3,500 people. The City of Lebanon's well field ser\'es about 5,000 people. Based on information obtained from Warren County, some area residents may obtain drinking water from private wells. Previous investigation data reported that 504 private wells serving 1,379 people were located within a 4-mile radius of the site. No drinking water intakes are located within 15 miles downstream of die former Peters Cartridge facility (PRC, 1994 and 1996).

2.3 Site Conditions

A series of environmental investigations has been conducted in Area A, beginning in 1987. Since 1992 the Ohio EPA has conducted several site assessment and screening evaluations focused in and around Area A. Soil, culvert samples, and groundwater were sampled during these investigations. Historic sampling locations are shown on Figure 9. In addidon, a fish tissue study was conducted for the Ohio EPA in 1999. Data from these investigations indicated that soils in Area A had been impacted by lead, copper, mercury, and Freon-113. A discussion of these data follows.


PRAO and ICT Site Operat ional History

2.3.1 Soi l

Copper, lead and mercury were used in manufacturing operations conducted at the former Peters Cartridge site. Nickel may also have been used around 1930 in the manufacture of casings (Schiffer, 2002). Nickel concentrations have not been detected in soils above background levels (Ohio EPA, 1999). Lead has been detected in soils at concentrations up to 301,000 milligrams per kilogram (mg/kg). Copper and mercury have been detected in soils at concentrations up to 47,500 mg/kg and 17.8 mg/kg, respectively.

The areas identified by Ohio EPA with elevated concentrations (above background) are areas where historic manufacturing or salvage operations had been conducted. For example, elevated concentrations of lead were identified near the shot towers, blacksmith shop, and where lead slue swaging and annealing operations were conducted. Elevated copper concentrations were detected in the salvage area on the west comer of the site (referred by Ohio EPA as the salvage/hearth area), and elevated mercury concentrations were detected aroimd the primer building (R-9) (refer Figure 10).

Elevated metals concentrations were primarily detected in surficial soils, within 1 foot bgs (Ohio EPA, Appendix A). Elevated metals concenfrations have also been detected LQ soils beneath fill materials at depths up to 12 feet bgs in Area A (QSource, 1987). Fill material was encountered primarily in Area A, particularly in the northwest salvage area. Based on site history and historic data from the northem portion of Area B, metal impacts in Area B are likely to be confined to surficial soils, as minimal fill materials are anticipated to be present. In addition, the primary use of Area B facilities was storage of raw/fmished materials and conveyance of water and utility lines. Thus the extent of impacts to soils in the area is expected to be limited.

Soils and groundwater between buildings R-3 and R-9 were impacted by Freon-113. The compound was used in LensCrafters' operations and is believed to have been released through the septic system which discharged to a leach field located northwest of building R-9. Freon-113 had been detected in soils at concentrations up to 0.34 milligrams per kilogram (mg/kg) and in groimdwater at concentrations up to 0.699 milligrams per liter (mg/1). Soil and groundwater investigations and a limited cleanup action (i.e., septic system removal and soils excavation) to address the release of Freon-113 to soil and groimdwater were completed in Area A between 1990 and 1993. Results from ambient air sampling conducted during remediation activities indicated that Freon-113 was not detected in air samples. The former leach field area is now covered by landscaping (lawn, trees and shrabs). Following completion of the remedial activities and confirmatory sampling, the U.S. EPA and Ohio EPA agreed no fiirther action regarding Freon-113 was warranted. Data from the investigation and remediation activities for the septic system is included in Appendix A.

2.3.2 Groundwater and Surface Water

Shallow groundwater in Area A was encountered at approximately 15 feet bgs, and flows to the north toward the river, following the bedrock topography (PRC 1996). Based on groundwater elevation data from public supply wells, deeper groundwater in the bedrock may flow to the southwest. Surface water flows to the north following the ground surface

3865_PRAOJCT_3.0 10 Dublin, OH


topography. Most surface water runoff flows to the LMR, with some infiltration occurring in unpaved areas.

Groundwater and surface water elevation data indicate that the LMR is in communication with shallow groundwater. Based on historic data, copper and mercury have not been detected above background levels in groundwater at the site. Lead has been sporadically detected in groundwater, with lead concentrations up to 52 |ig/L historically detected ia a sample from the well near the shot tower (QSource, 1989). It is worth noting that the groundwater samples exhibited considerable turbidity, which may indicate the lead results were associated with soils in the area rather than groundwater.

Lead has not been detected in groundwater samples from off-site municipals wells, with the exception of one sample, which was collected in 1996 from Hamilton-Deerfield Well No. 5. A concentration of 4 ^g/L lead was reported for the original sample, but lead was not detected in the duplicate sample collected from the well. Metals have not been detected above maximum contaminant levels in historic groundwater monitoring samples collected from Hamilton-Deerfield mtmicipal supply wells (Warren Cotmty Water, 2004).

2.3.3 Culvert Samples

Culvert samples were collected from drainage features on-site and from several outfalls and culverts upstream and downstream from the site during historic site investigations. Drainage channels upgradient from the former operating areas are well-incised, erosional features, while culverts and outfall areas on the flatter lower section of the site are generally depositional areas. Upgradient samples collected in erosional areas during previous investigations may also be referred to as soil, or swale samples. Lead and copper have been detected in culvert samples at concentrations ranging up to 446 mg/kg and 45.7 mg^g, respectively (PRC, 1996). The highest concentrations were detected near the western end of the site, in the vicinity of the salvage area and west of the former KMOP government plant. Mercury has also been detected in on-site and off-site culvert samples (Ohio EPA, 1996 and 1999). Historic data from 1996 showed mercury concentrations were generally higher in on-site samples than in an upstream, background sample. Conversely, data from 1999 showed mercury concentrations in upsfream (backgroimd) samples were higher than concentrations detected in on-site samples.

2.3.4 Fish Tissue Study

Fish tissue samples collected in 1999 by Ohio EPA from fish in the LMR in the site vicinity contained mercury at concentrations ranging from 0.128 mg/kg to 0.385 mg/kg. Lead and copper were not detected in the fish tissue samples. The results showed no relation between proximity to the site and mercury concentrations in fish tissue. (Ohio EPA, 1999)

2.4 Site Conditions Summary

Based on historic data collected to date, the site is impacted by copper, lead and mercury which are associated with the former munitions manufacturing operations. The impacts



are generally confined to surface soils in former manufacturing and storage areas on-site. The impacts likely resulted from historic surficial releases to site soils. Filling operations over time, particularly in the former salvage area, near the power station (R-l9) and southwest end of Building R-l may have resuhed in impacted soils being present at depths near the groundwater table.

Recent operations by LensCrafters resulted in Freon-113 impacts to soil and groundwater in Area A at the site. These impacts are limited in extent, and have been remediated. Ohio EPA and U.S. EPA have indicated that no further action is required, with regard to Freon.

Currently, Area A, where the main manufacturing operations were historically conducted, is paved with asphalt/concrete. Area B is covered by dense vegetation. Given the site history, impacts from potential constituents of concem (COCs, i.e., copper, lead and mercury) are likely confined to surface soils where no filling took place and to surface and subsurface soils in fill areas on-site. Fill materials, in thickness estimated up to 10 feet, are present in Area A.

Minimal fill materials are anticipated to be present in Area B, which was primarily used for storage and conveyance of water and other utilities. Facilities in Area B were generally constmcted on grade and only a few of the facilities were used for materials processing (i.e., mixing) or other manufacturing operations. Similar to Area A, impacts in Area B are anticipated to be limited to surficial soils (within 5 feet bgs) in and around the historic storage/process facilities and shooting ranges. Soils in surface water drainage features on-site, including the natural ravines in Area B and man-made channels in Area A may also be impacted by COCs.

Due to the low solubility of copper, lead and mercury, groundwater impacts are unlikely. Because of the low solubility of these compounds and the distance to the nearest groundwater extraction wells (located approximately 0.3 miles downsfream adjacent to the LMR), the potential for impacts to drinking water is considered low. To support development of the site hydrogeologic model however, it is recommended that the potential for migration of COCs into groimdwater be evaluated as part of the RI/FS.

Residual and waste materials within existing stmctures on site are limited, as the majority of internal stmctures and all former machinery have been removed. During the RI phase, all unoccupied buildings will be surveyed for residual material, which will be identified and subject to interim remedial actions. The lead impacted target range sands in building R-23 will be removed as an interim measure during the Rl process.

2.5 Potential Exposure and Migration Pathways

The majority of the site is either paved or heavily vegetated. Only the northem portion of the property, which is covered by asphalt/concrete paving and landscaping, is utilized for commercial/industrial use. As a result, the potential risks to site users from short-term dermal contact and or inhalation of dust are limited. However, disturbance of site soils during investigation and any ftiture redevelopment activities may create dust, and increase the potential for workers to contact impacted soils. As a consequence, these exposure pathways will be mitigated during investigation and development of the site.


PRAO and ICT S i t e O p e r a t i o n a l H i s t o r y

Under current site conditions, potentially complete migration and exposure routes for site COCs are associated with stormwater runoff and potential discharge to the LMR. Investigation activities indicate that impacted soils have been detected in surface water drainage channels at the site. It is recommended that during the RI/FS process, a comprehensive investigation program be developed that includes assessment of potential COCs on and off-site. Based on the results of this investigation. Interim Measures and Corrective Measures can be designed and implemented in order to mitigate potential migration and/or risks from site COCs.

Complete migration pathways that may result in exposure to human and ecological receptors will be identified during the site characterization process. Based on current site data available, potential human receptor exposure pathways of concem may be:

Q Dermal contact and ingestion of soils

Q Inhalation of dust during intmsive activities (i.e., subsurface investigation, site redevelopment)

Potential ecological receptor exposure pathways of concem may be:

Q Direct contact and ingestion of soils by terrestrial receptors;

• Direct contact and ingestion of culvert soils by aquatic receptors

Q Direct ingestion of prey items by terrestrial biota

U Direct ingestion of prey items by aquatic biota


PRAO and ICT Prel iminary Remedial Ac t ion Object ives

3.0 PRELIMINARY REMEDIAL ACTION OBJECTIVES

The following PRAOs were developed based on the site information and investigation findings available to date. The general objectives of the PRAOs are to:

• Characterize site conditions in Area A and Area B,

• Evaluate potential risks that site COCs may pose to human health and/or the environment under current and possible future site uses,

Q Support development of site specific clean-up objectives, and

Q Assess the need for and evaluate appropriate remedial actions that may be necessary in order to mitigate potential risks to human health and the environment from COCs at the site.

The PRAOs for the site follow.

• Investigate, identify, and address all COC (i.e., copper, lead and mercury) impacted residual materials in unoccupied buildings

• Remove residual target range sands in Building R-23

Q Evaluate the potential presence and extent of site COCs along the former rail spur.

Q Evaluate the potential presence and extent of site COCs in surface and subsurface soils at the site through implementation of soils sampling and analysis

• For ash-like fill materials encoimtered in Area A, assess the potential presence of 13 metals and 16 polynuclear aromatic hydrocarbons (PAHs) identified on the U.S. EPA priority pollutant list (PPL).

1̂ For fill materials in the former reservoir, assess the potential presence of 13 metals and 16 PAHs identified on the PPL. Analysis for PPL analytes not identified as site-wide COCs will not be necessary if appropriate written documentation is obtained identifying the source of the fill materials as native soils from the Warren County property adjacent to the south end of the site.

• Assess the potential presence of COCs in surface water and soils associated with drainage areas on-site, and at discharge points along the river via sampling and analysis.

• Assess the potential presence and extent of site COCs in groundwater via implementation of a groundwater investigation utilizing existitig wells. As noted above, the U.S. EPA and Ohio EPA have determined no fiirther action is required for Freon-113 at the site. Therefore this compound is not considered a COC at the site and will not be evaluated in the groundwater investigation.

• Evaluate the potential presence and extent of site COCs in off-site soils and surface water for assessment of backgroimd conditions and comparison with on-site data.



• Conduct air monitoring during site investigative, operational, and/or development activities that may generate dust to assess the potential for airborne transport of site COCs

• Evaluate the geophysical and geochemical properties of site soils and groundwater to assess the potential fate and transport of COCs in the subsurface

• Evaluate potential human and ecological risks from site COCs

Q Develop site specific clean-up objectives and/or appropriate and relevant alternative remedies to address potential risks from COCs at the site

• Implement appropriate remedial actions to address areas with significant impacts that may pose a risk to human health and/or the environment

• Implement a long-term management plan to mitigate the potential for present and future occupant exposures to site COCs, and to prevent offsite migration of site COCs

To achieve these objectives, a RI/FS work plan will be developed. The RI/FS will address completing the site characterization and development of a site conceptual model. Based on the findings of the investigation, human health and ecological risk assessments will be completed, and appropriate remedial alternatives will be evaluated and implemented to mitigate any risks that are identified.

The RI will be conducted in a manner that maximizes the use of investigation data as it becomes available to minimize data gaps in site characterization. Initial sampling will be focused on-site. Background samples will also be collected off-site for comparison with on-site data. Sampling will be conducted using a grid system supplemented with biased sampling focused in and around former operational areas and structures/facilities. Sampling will also be conducted using a grid system across the site in non-operational areas. Backgroimd soil samples will be collected from undisturbed woodlands and agricultural areas in the site vicinity. Soil and sediment samples will be analyzed in the field using x-ray fluorescence spectrometry (XRF) techniques. Replicate samples (frequency of 5%) will also be analyzed using SW-846 methods by a NELAP certified laboratory.

The groundwater investigation will include installation of new wells on-site near the LMR, in areas of where significant fill is observed, and/or areas where soil impacts extend to depth. As a result of this approach, groundwater monitoring wells will be primarily located in the lower, operational portion of the site. Groundwater samples will be analyzed to assess the potential presence of COCs and to obtain geochemical parameters needed for site characterization and subsurface COC fate and transport evaluations.

The surface water, soil and groundwater data collected during the investigation will be used to develop a surface water and sediment sampling plan for the LMR. Based on current information available, sediment/river sampling locations will likely be identified upstream, adjacent to and downstream of site surface water discharge points, downstream of the army reserve center, and areas adjacent to the former KMOP Government Plant Polnol (lead styphnate) discharge area. Details regarding proposed sampling locations.



methodologies, analysis, and sampling frequency will be provided in the RI/FS workplan to be developed for this site.



3.1 PRAO Summary

The site is impacted by copper, lead and mercury. Historic investigations conducted to date have focused primarily on Area A with some overlap into the northem portion of Area B. Historic sampling data indicate that soil impacts are generally confmed to surficial and shallow subsurface soils in former operational and storage areas at the site. In select areas on site, historic fill activities may have resulted in soil impacts extending to depths near groundwater.

The previous investigation data show copper, lead and mercury have been detected in soils from culverts and swales at the site. The concentrations detected were generally higher in on-site samples than in off-site samples. Lead was sporadically detected in on-site groundwater samples, but generally has not been detected in samples from off-site municipal water supply wells. Copper and mercury have not been detected above background concentrations in on-site groundwater. Historically, metals have not been detected above maximum contaminant levels in downgradient groundwater monitoring well samples collected by the Warren Coimty Water and Sewer Department.

The majority of the site is paved or heavily vegetated. A few small businesses occupy portions of buildings R-3 and R-9 in Area A. Area B is vacant and not in use. Under the current site conditions, potential migration pathways and exposure routes for human receptors are likely to be direct contact and incidental ingestion of soils, and inhalation of dust generated from subsurface investigation and/or site redevelopment activities. Potential ecological receptor exposure/migration pathways of concern are likely to be direct contact and ingestion of soils by terrestrial receptors, direct contact and ingestion of culvert soils by aquatic receptors, and direct ingestion of prey items by terrestrial biota and/or aquatic biota.

The site conditions, potential migration pathways/exposure routes, and the PRAOs identified herein were developed based on the data currently available for the site. Ln accordance with the AOC and in order to meet the PRAOs for the site, a RI/FS Work Plan will be prepared and submitted to Ohio EPA and U.S. EPA. As noted above, it is anticipated that RI sampling activities will be implemented in a manner that allows for effective use of data as it becomes available to minimize data gaps in site characterization. The approach for the investigation will be outlined in the RI/FS work plan and supporting documents to be developed for the site. Following the approval of the RI/FS and in accordance with the project schedule outlined in the AOC, subsequent activities pursuant to the RI and AOC will commence.


PRAO and ICT Identi f icat ion of Candidate Technologies

4.0 IDENTIFICATION OF CANDIDATE TECHNOLOGIES

The candidate technologies discussed below were identified using the guidelines in sections 1.4.3 and Appendix C of the USEPA document. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA. The process by which remedial technologies are evaluated is described in the guidance as a four step process. The four steps and their corresponding documentation are:

• Identifying remedial action objectives - Preliminary Remedial Action Objectives Technical Memorandum

• Identifying potential treatment, resource recovery, and containment technologies that will satisfy these objectives - Identification of Candidate Technologies Memorandum

• Screening the technologies based on their effectiveness, implementability, and cost - Alternatives Screening Technical Memorandum

• Assembling technologies and their associated containment or disposal requirements iato alternatives for the impacted media at the site - Comparative Analysis of Alternatives Technical Memorandum

Candidate technologies are identified below for all media at the site currently known to be impacted. Candidate technologies will be evaluated on the basis of applicable or relevant and appropriate requirements (ARARs), effectiveness, implementability and cost during the RI/FS process.

4.1 Soil

The currently available data for soil indicate that site COCs are copper, lead and mercury. Strategies for the remediation of COC-impacted soils and the technologies that support each remedial strategy include:

1. Removal of impacted media and transport to a permitted waste disposal facility

2. Removal of impacted media and containment on-site via an applied cap

3. In-situ containment via constmction of an engineered cap over unpacted portions of the site

4. Containment via constmction of an on-site engineered placement/management unit

5. In-situ treatment via applied biological processes

• Phytoremediation-Temova.1 of COCs by certain plants

6. In-situ stabilization via applied chemical process

• Earth moving equipment-Mbimg and application of stabilizing agent

7. In-situ stabilization via applied physical process

1̂ Vitrification Mw//-heating of soils to melting point, fume capture


PRAO and ICT Identi f icat ion of Candidate Technologies

8. Ex-situ treatment

• Soil washing -separation of finer particles associated with COCs

• Electrochemical -separation of metals from soil using electricity

9. No Action-COC concentrations in soils below ARARs

4.2 Groundwater

The currently available data for groundwater indicate that lead may be a COC in groundwater. Strategies for the remediation of lead in groundwater and the technologies that support each remedial strategy include:

1. Ex-situ treatment

Q Pump and treat-cemowe impacted groundwater, carbon absorption for lead

2. In-situ treatment

• Permeable Reactive Barrier-immobilize lead through use of chemical reaction

• Bioremediation-trees or plants take up impacted groundwater

O Electrokinetics-mobilize COC to electrodes

3. Institutional Confrols

1̂ Deed restriction/Well restriction-institutional controls to prevent access to impacted groundwater

4. No Action

• Chemical and spatial analysis-COC concentrations in soils below ARARs

3865_PRAOJCT_3.0 19 Dublin, OH

PRAO and ICT R e f e r e n c e s

5.0 REFERENCES DuPont. 2004. History of Constmction Kings Mills Ordnance Plant Kings Mills Ohio.

Gotten, Carl. 2004. Conversation with Warren County Water and Sewer Department Superintendent of Operations and URS staff, June 28.

Office of Emergency and Remedial Response, U.S. Environmental Protection Agency (USEPA), 1988. Guidance for Conducting Remedial Investigations and Feasibility Smdies Under CERCLA, EPA/540/G-89/004, OSWER Directive 9355.3-01. October.

PRC Environmental Management, Inc. (PRC), 1994. Screening Site Inspection Site Evaluation Report Peters Cartridge Factory (also Known as Kings Mills Technical Center) 1915 Grandin Road Kings Mills, Ohio 45034. September 30.

PRC Environmental Management, Inc. (PRC), 1996. Screening Site Inspection Site Evaluation Report Peters Cartridge Factory 1415 Grandin Road Kings Mills, Warren County, Ohio. December 20.

PRC Environmental Management, Inc. (PRC), 1999. Expanded Site Inspection Report Peters Cartridge Factory Site 1415 Grandin Road Kings Mills, Warren County, Ohio. September 29.

QSource Engineering, Inc. (QSource), 1987. Environmental Site Assessment Kings Mills Technical Center Kings Mills, Ohio. December 21.

State of Ohio Environmental Protection Agency (Ohio EPA), 1999. Fish Tissue Study of the Little Miami River. August 19.

Schiffer, Tom. 2002. Peters and King the Birth and Evolution of the Peters Cartridge Co. and the King Powder Co., Krause Publications, lola, WI.

Sharpe, Philip B., 1938 and 1947. The Rifle in America, 3"''' edition, William Morrow and Company, quoted in Schiffer, Tom. 2002. Peters and King the Birth and Evolution of the Peters Cartridge Co. and the King Powder Co., Krause Publications, lola, WI.


TABLES

TABLE 3 PROJECT SCHEDULE FOR MAJOR DELIVERABLES

DELIVERABLE DUE DATE

Preliminary Remedial Action Objectives (PRAO) Technical Memorandum

30 calendar days after the effective date of the Administrative Order On Consent (AOC).

Quality Management Plan (QMP) QMP is due 30 days after the effective date of the AOC.

Statement of Qualifications Statement of qualifications is due 30 days after the effective date of the AOC for all personnel performing work under the AOC.

RI/FS Work Plan RI/FS Work Plan is due within 60 calendar days after approval of the PRAO. Final RI/FS Work Plan due 21 calendar days after receipt of United States Environmental Protection Agency's (USEPA's) comments on the draft RI/FS Work Plan. Any subsequent revisions, if required, are due within 15 calendar days of receipt of USEPA's comments.

Sampling and Analysis Plan (SAP) SAP is due within 60 days of the receipt of USEPA's approval of the PRAO Technical Memorandum. Final SAP is due 21 calendar days after receipt of USEPA's comments on the draft SAP. Any subsequent revisions, if required, are due within 15 calendar days of receipt of USEPA's comments. The SAP is composed of the Field Sampling Plan (FSP), Quality Assurance Project Plan (QAPP), and Health and Safety Plan (HASP).

Technical Assistance Plan (TAP) TAP due 30 calendar days after the effective date of the AOC. Final TAP due 21 calendar days after receipt of USEPA's comments on the draft TAP. Any subsequent revisions, if required, are due within 15 calendar days of receipt of USEPA's comments.

Implementation of the TAP- Quarterly Progress Reports

Ten calendar days after the end of each calendar quarter. The first report is due at the end of the quarter during which the final TAP is approved.

Site Characterization Technical Memorandum

Within 180 calendar days of USEPA's approval of the RI/FS Work Plan or the SAP.

Human Health Risk Assessment Report Human Health Risk Assessment Report due 60 calendar days after receipt of USEPA's comments on the Site Characterization Technical Memorandum. Final Human Health Risk Assessment Report due 21 calendar days after receipt of USEPA's comments on the draft Human Health Risk Assessment Report. Any subsequent revisions, if required, are due within 15 calendar days of receipt of the USEPA's comments.

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Ecological Risk Assessment Report

RI Report

Identification of Candidate Technologies Memorandum

Treatability Testing Work Plan, SAP, HASP, and Evaluation Report Remedial Action Objectives Technical Memorandum

Alternatives Screening Technical Memorandum Comparative Analysis of Alternatives Technical Memorandum

Ecological Risk Assessment Report due 60 calendar days after receipt of USEPA's comments on the Site Characterization Technical Memorandum. Final Ecological Risk Assessment Report due 21 calendar days after receipt of USEPA's comments on the draft Ecological Risk Assessment Report. Any subsequent revisions, if required, are due within 15 calendar days of receipt of USEPA's comments. RI Report due 60 calendar days after receipt of USEPA's comments on the Site Characterization Technical Memorandum. Final RI Report due 21 calendar days after receipt of USEPA's comments on the draft RI Report. Any subsequent revisions, if required, are due within 15 calendar days of receipt of USEPA's comments. Within 30 days of the effective date of the AOC. Any subsequent revisions, if required, are due within 15 calendar days of receipt of USEPA's comments

As indicated in the USEPA approved RI/FS Work Plan, if treatability studies are identified as necessary. With the RI Report - 60 calendar days after receipt of USEPA's comments on the Site Characterization Technical Memorandum. Within 21 calendar days of submission of the Remedial Action Objectives Technical Memorandum. Twenty-one (21) calendar days after receipt of

USEPA's comments on the Alternatives Screening Technical Memorandum. Any subsequent revisions, if required, are due within 15 calendar days of receipt of USEPA's comments

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Draft Feasibility Study (FS)

Monthly Progress Reports

Draft FS due 21 calendar days after receipt of USEPA's comments on the Comparative Analysis of Alternatives Technical Memorandum. Final FS Report due 21 calendar days after receipt of USEPA's comments on the draft FS Report. Any subsequent revisions, if required, are due within 15 calendar days of receipt of USEPA's comments. By the IS"' day of each month, following the effective date of the AOC.

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EPA Region 5 Records Ctr.

Documents

Transcript of EPA Region 5 Records Ctr.