REMOVAL ASSESSMENT REPORT FOR LANE PLATING WORKS ...
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REMOVAL ASSESSMENT REPORT
FOR
LANE PLATING WORKS INCORPORATED
5322 BONNIE VIEW ROAD
DALLAS, DALLAS COUNTY, TEXAS
Prepared for
U.S. Environmental Protection Agency Region 6
Will Lombard, Project Officer
1445 Ross Avenue
Dallas, Texas 75202
Contract No. EP-W-06-042
Technical Direction Document No. 5/WESTON-042-16-004
WESTON Work Order No. 20406.012.005.0992.01
NRC No. N/A
CERCLIS ID TXN000607031
FPN No. N/A
EPA OSC William Rhotenberry
START-3 PTL Jose L. Ojeda
Prepared by
Weston Solutions, Inc.
Cecilia H. Shappee, P.E., Program Manager
5599 San Felipe, Suite 700
Houston, Texas 77056
(713) 985-6600
July 2016
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EXECUTIVE SUMMARY
On 10 March 2016, the U.S. Environmental Protection Agency (EPA) tasked Weston Solutions,
Inc. (WESTON®), the EPA Region 6 Superfund Technical Assessment Response Team
(START-3) contractor, to perform a Removal Assessment (RA) at the Lane Plating Works, Inc.
site located in Dallas, Dallas County, Texas (Technical Direction Document [TDD] No.
5/WESTON-042-16-004). The RA was initiated in response to a request by the Texas
Commission on Environmental Quality (TCEQ) to EPA Region 6 stating enforcement actions
had been exhausted following an Agreed Order Follow-Up (Agreed Order Docket No. 2011-
0662-IHW-E) and Compliance Evaluation Investigation (CEI) conducted 21 October 2014.
START-3 RA activities were completed between 05 April 2016 and 13 April 2016 and included
performing air monitoring and compiling photographic documentation of containers within the
plating facility; compiling logbook and photographic documentation of on-site RA activities; and
collecting soil and liquid waste samples for analytical testing.
Soil sampling around the facility footprint was conducted 12 April 2016 through 13 April 2016
extending to a depth of approximately 3 inches below ground surface (bgs), while liquid waste
sampling was conducted 13 April 2016. A total of 36 soil samples and 4 liquid waste samples
were collected to determine the nature and extent of site-related, hazardous constituents
associated with electroplating waste (plating waste) in on-site soils, and to verify if liquids,
contained in an unknown number of drums and totes, were considered hazardous substances.
Soil and liquid samples were shipped to TestAmerica Laboratories in Houston, Texas, for
analysis. Soil samples were submitted for analysis of Metals and Hexavalent Chromium [Cr
(VI)]. Liquid waste samples were submitted for analysis of Metals, Hexavalent Chromium [Cr
(VI)], Corrosivity (pH), and Sulfide and Cyanide Reactivity. Soil analytical data was compared
to the EPA Regional Screening Levels (RSLs), Industrial Soil (THQ = 1.0), May 2016. The
liquid waste characterization results were compared to 40 CFR Part 261.
Based on the analytical results, hexavalent chromium, lead, and mercury contaminated soil was
present around the footprint of the building. Hexavalent chromium was reported in 17 grids
exceeding the EPA RSL of 6.3 mg/Kg. Hexavalent chromium contaminated soil ranged in
concentration from 167 mg/Kg (Grid E7) to 5,620 mg/Kg (Grid G7). Lead exceeded the EPA
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RSL of 800 mg/Kg in six grids. Mercury was observed above instrument detection limits in
several grids but only exceeded in one grid above the EPA RSL of 46 mg/Kg.
Four liquid waste samples were collected from two on-site totes and one tank labeled as a “rinse
water tank” and analyzed to confirm the presence of hazardous substances. Based on the
laboratory results, the liquid waste by definition is hazardous due to the characteristic of
corrosivity with a pH less than 2. Concentrations ranged from 0.6 to 2.15. Total chromium
present in the liquid samples ranged from 105,000 mg/Kg to 296,000 mg/Kg.
START-3 conducted air monitoring for acid gas, mercury vapors, and volatile organic
compounds (VOCs) during the preliminary site visit and throughout the soil and liquid waste
sampling activities. No readings above instrument detection levels were reported.
START-3 has prepared this Removal Assessment Report to describe the technical scope of work
that was completed as part of the TDD No. 5/WESTON-042-16-004 under Contract No. EP-W-
06-042 for EPA Region 6. The EPA On-Scene Coordinator (OSC) was William Rhotenberry.
The START-3 Project Team Lead (PTL) was José L. Ojeda.
The EPA Task Monitor did not provide final approval of this report prior to the
completion date of the work assignment. Therefore, Weston Solutions, Inc. has
submitted this report absent the Task Monitor’s approval.
The EPA Task Monitor has provided final approval of this report. Therefore,
Weston Solutions, Inc. has submitted this report with the Task Monitor’s approval.
X
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TABLE OF CONTENTS
Section Page
EXECUTIVE SUMMARY ................................................................................................. ES-I
1 INTRODUCTION.......................................................................................................... 1-1
1.1 PROJECT OBJECTIVES ...................................................................................... 1-1
1.2 SCOPE OF WORK ................................................................................................ 1-2
1.3 REPORT FORMAT .............................................................................................. 1-2
2 SITE BACKGROUND .................................................................................................. 2-1
2.1 SITE LOCATION ................................................................................................. 2-1
2.2 SITE DESCRIPTION ............................................................................................ 2-1
2.3 POTENTIAL SOURCES OF HAZAROUS MATERIALS .................................... 2-1
2.4 OPERATIONAL AND REGULATORY HISTORY ............................................. 2-2
2.5 SUMMARY OF PREVIOUS INVESTIGATIONS ................................................ 2-2
3 ACTIONS TAKEN ........................................................................................................ 3-1
3.1 SOIL SAMPLING ................................................................................................. 3-1
3.2 LIQUID WASTE SAMPLING .............................................................................. 3-2
4 ANALYTICAL METHODOLOGY .............................................................................. 4-1
4.1 SOIL SAMPLE ANALYSES ................................................................................ 4-1
4.2 LIQUID WASTE SAMPLE ANALYSES.............................................................. 4-1
4.3 DATA VALIDATION ........................................................................................... 4-2
5 SUMMARY OF ANALYTICAL RESULTS ................................................................ 5-1
5.1 SOIL SAMPLES RESULTS .................................................................................. 5-1
5.2 LIQUID WASTE SAMPLE RESULTS ................................................................. 5-2
5.3 AIR MONITORING RESULTS ............................................................................ 5-2
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LIST OF APPENDICES
Appendix A Removal Assessment Quality Assurance Sampling Plan (QASP)
Appendix B Digital Photographs
Appendix C Site Logbook
Appendix D Analytical Data Packages
Appendix E Data Validation Reports
Appendix F Technical Direction Document No. 5/WESTON-042-16-004
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LIST OF FIGURES
Figure 1-1 Site Location Map
Figure 2-1 Site Area Map
Figure 2-2 Site Property Map
Figure 3-1 Soil Sample Location Map
Figure 4-1 Soil Sample Exceedance Map
Figure 4-2 Soil Sample Results Map - Hexavalent Chromium
Figure 4-3 Soil Sample Results Map - Lead
Figure 4-4 Soil Sample Results Map - Mercury
LIST OF TABLES
Table 5-1 Summary of Soil Analytical Results
Table 5-2 Summary of Liquid Waste Analytical Results
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1 INTRODUCTION
Weston Solutions, Inc. (WESTON®), the EPA Region 6 Superfund Technical Assessment and
Response Team (START-3) contractor, was tasked by the U.S. Environmental Protection
Agency (EPA) Region 6 Emergency Management Branch (EMB) under Contract Number EP-
W-06-042 and Technical Direction Document (TDD) No. 5/WESTON-042-16-004 (Appendix F)
to conduct a Removal Assessment (RA) at the Lane Plating Works, Inc. site located in Dallas,
Dallas County, Texas. This RA was initiated in response to a request by the Texas Commission
on Environmental Quality (TCEQ) to EPA Region 6 stating enforcement actions had been
exhausted following an Agreed Order Follow-Up (Agreed Order Docket No. 2011-0662-IHW-E)
and Compliance Evaluation Investigation (CEI) conducted 21 October 2014. A Site Location
Map is provided as Figure 1-1. All figures and tables are provided as separate portable
document format (PDF) files. START-3 has prepared this report to describe the technical scope
of work that was performed during the RA at the Lane Plating Works, Inc. site.
1.1 PROJECT OBJECTIVES
START-3 provided technical support to EPA for performance of the Lane Plating Works, Inc.
site RA activities. The objectives of the RA were:
To determine the nature and extent of potentially hazardous substances associated with
electroplating waste (plating waste) in on-site soils.
To verify if liquids contained in an unknown number of totes and rinse water tanks
located within the facility contain hazardous substances.
The objectives of the RA were achieved by evaluating data obtained during the field
investigation through the collection of soil samples and liquid waste samples and reviewing
available background information including the TCEQ CEI reports. START-3 activities
included establishing a 50-foot by 50-foot grid system around the facility footprint. Five-point
composite surface soil samples were collected at a depth of 3 inches below ground surface (bgs)
within each grid. Liquid waste samples were collected from totes and rinse water tanks within
the facility for hazard characterization.
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1.2 SCOPE OF WORK
The RA scope of work included the following activities:
Develop a site-specific Quality Assurance Sampling Plan (QASP) and health and safety
plan (HASP)
Conduct air monitoring inside the facility for acid gas, mercury vapors, and volatile
organic compounds (VOCs)
Establish a 50-foot by 50-foot grid around the facility footprint and collect five-point
composite soil samples.
Collect liquid waste samples from totes and rinse water tanks within the facility.
Review analytical soil sample data results and compare those analytical results to EPA
Regional Screening Levels (RSLs), Industrial Soil (THQ = 1.0), May 2016.
Review analytical waste sample data results and determine if the liquid contains
hazardous substances.
Samples were collected and analyzed in accordance with the START-3 QASP. A copy of the
QASP is located in Appendix A. Digital photographs of RA activities are included in Appendix
B.
1.3 REPORT FORMAT
This report has been organized as follows:
Section 1 - Introduction
Section 2 - Site Background
Section 3 - Actions Taken
Section 4 - Analytical Methodology
Section 5 – Summary of Analytical Results
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2 SITE BACKGROUND
Information regarding site location, site description, and potential sources of hazardous material,
operational and regulatory history, and summary of previous investigations is presented in the
following subsections.
2.1 SITE LOCATION
The site is located at 5322 Bonnie View Road in Dallas, Dallas County, Texas, within a mixed
commercial and residential area. The approximate center of the site is located at Latitude
32.6878557° North and Longitude 96.7692897° West. The site encompasses approximately
4.655 acres according to the Dallas County Central Appraisal District. A relative of the owner
resides in a home located adjacent to, on the north side of the site; a residential area is located
0.25-mile northwest; to the east approximately 7 miles is H. Grady Spruce High School; and 0.3
miles to the south is Five Mile Creek that discharges into the Trinity River. A barbed-wire fence
and locked chain-link fence surrounds the property, and the building is locked with the windows
boarded up. There is no access to the site except by key at the locked gate. Site topography and
surface water drainage appears to slope to the south-southeast. A Site Area Map is provided as
Figure 1-2. A Site Property Map is provided as Figure 2-2.
2.2 SITE DESCRIPTION
Lane Plating Works, Inc. is an abandoned electroplating facility that contains an unknown
number of drums and totes, containing electroplating wastes from operations that ended in 2015.
Lane Plating Works, Inc. is currently controlled by Stag Management, Inc., a court-appointed
trustee. Typical electroplating process waste includes acids, bases, flammables, oxidizers,
cyanides, chromium-contaminated solids (sludge) and liquids, and Resource Conservation
Recover Act (RCRA) non-hazardous solids and liquids. The number and condition of the drums
and totes containing the electroplating wastes are not known at this time.
2.3 POTENTIAL SOURCES OF HAZAROUS MATERIALS
Information concerning the known or potential hazardous waste source areas at the site and the
constituents thought to be associated with each source are discussed in this subsection.
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Based on the TCEQ investigation conducted on 04 November 2015 and on TCEQ sampling
activities on 19 November 2015, former site activities that contributed to potential sources
include the following:
Stripping metal parts of dirt, oil, grease, and scale in acid.
Grinding and buffing metal parts smooth prior to and during plating.
Pretreatment of metal parts using sodium hydroxide and sulfuric acid.
Copper plating using copper cyanide.
Zinc plating aluminum using nitric acid and zinc cyanide.
Nickel plating using nickel sulfate.
Chrome plating using chromic acid.
Electroplating wastewater treatment that included a surface impoundment.
Generation and storage of solid waste.
2.4 OPERATIONAL AND REGULATORY HISTORY
Lane Plating Works, Inc. has been in operation for over 50 years at the property as an
electroplating facility, conducting primarily (60-70%) hard chromium plating and cadmium
plating. Processes performed at the facility included chromate dips, chromic acid anodizing,
hard chrome plating, cadmium plating, black oxide coating, electroless nickel plating,
passivation, machining, and grinding. In addition to electroplating, the facility also operated a
lead melting pot used to repair anodes used in the plating baths. The facility housed two chrome
tanks, and according to TCEQ Air Compliance Section reports, the emission from the tanks was
controlled by a mesh-pad scrubber and mist eliminator fume hood system. The last updated
Notice of Registration (NOR), dated 18 January 2011, listed 10 hazardous wastes and 3 Class II
Industrial Solid Wastes.
2.5 SUMMARY OF PREVIOUS INVESTIGATIONS
Information regarding previous on-site investigations conducted by state regulatory agencies are
summarized in this section.
In February 2010, the TCEQ Dallas/Fort Worth (Region 4) office conducted an unannounced
investigation at the facility. Sixteen 55-gallon drums of hazardous plating waste were observed
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unlabeled and missing necessary identification and accumulation dates. A Notice of Violation
(NOV) letter was transmitted to the facility on 24 February 2010 for alleged violations of 30
Texas Administrative Code (TAC) 35.69 for failure to properly label hazardous waste containers.
On 19 January 2011, the TCEQ DFW office conducted an Industrial and Hazardous Waste
(IHW) CEI at the facility. Based on observations made during the CEI, it was determined that
soil sampling was necessary. As a result of the CEI, five alleged violations and one additional
issue regarding the rules for IHW were documented and formal enforcement action was initiated.
A proposed Agreed Order was issued to the facility on 5 July 2011. This Agreed Order directed
the facility to complete technical requirements, including immediately ceasing any additional
unauthorized discharges; removing all discharged industrial solid waste, visibly impacted soils,
and waste containers from the facility; properly disposing of waste at an authorized facility;
developing and implementing procedures to ensure that all containers storing hazardous waste
were removed within the allotted accumulation time limit and transported to a facility authorized
to accept the waste; submitting annual waste summaries for calendar years 2008 and 2009; begin
maintaining all records of all hazardous and industrial solid waste activities; and submitting an
Affected Property Assessment Report (APAR).
On 16 September 2014, the TCEQ Enforcement Division requested the TCEQ Region 4 office to
conduct an on-site investigation at Lane Plating Works, Inc. to determine if the facility had
complied with the Agreed Order.
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3 ACTIONS TAKEN
On 23 March 2016, EPA, TCEQ, and START-3 conducted a preliminary reconnaissance to
observe current site conditions and discuss project objectives for the RA. START-3 conducted
air monitoring within the building for acid gas, VOCs, and mercury vapors during the site visit.
During the preliminary reconnaissance, soil and liquid waste sampling strategies were discussed
between EPA and START-3 and included a systematic method for determining nature and extent
of hazardous constituents in on-site soils and verifying potentially hazardous liquids contained in
an unknown number of totes and drums within the facility.
Following the preliminary reconnaissance, EPA and START-3 developed a sampling strategy
that included establishing a 50-foot by 50-foot sampling grid surrounding the footprint of the
facility. On 05 April 2016, START-3 mobilized to the site and established 43, 50-foot by 50-
foot grids around the exterior facility utilizing a Trimble Pro-XRT Global Positioning System
(GPS) unit. The corner points of each grid were marked with pin flags and labeled. A Soil
Sample Location Map is provided as Figure 3-1.
START-3 conducted soil and liquid waste sampling activities from 12 through 13 April 2016.
All sampling activities were completed in accordance with the START-3 QASP. Any deviations
to the QASP was discussed with the EPA OSC and noted in the field logbook. Site logbook
notes are included in Appendix C. Sample nomenclature reflected the grid location, date, sample
matrix, sample depth, and sample type (field sample vs. duplicate sample). Detailed soil and
liquid waste sampling information is included in the following subsections.
3.1 SOIL SAMPLING
START-3 conducted soil sampling to determine the nature and extent of hazardous substances
associated with electroplating waste (plating waste) in on-site soils. During sampling activities,
30 composite surface soil samples (29 normal samples and 1 field duplicate sample) were
collected from 0 to 3-inches bgs using dedicated plastic scoops. The grids sampled included the
following:
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A1 A7 B7 C7 D7 F7 H1 H5
A2 B1 C1 D1 E1 G1 H2
A3 B2 C2 D2 E7 G5 H3
A6 B6 C6 D6 F1 G7 H4
A total of five grab samples plus one field duplicate was collected using dedicated plastic scoops
from grids LPW01-E6, LPW01-E6 (duplicate), LPW02-F7, LPW03-D5, LPW04-E2, and
LPW05-G3 at the direction of the EPA OSC.
Composite soil samples were homogenized in a dedicated disposable plastic bag and
immediately transferred into a pre-cleaned 4-ounce glass jar with a Teflon-lined lid. Grab soil
samples were collected and immediately placed in pre-cleaned 4-ounce glass jar with a Teflon-
lined lid. All soil samples collected were stored in a cooler with ice.
3.2 LIQUID WASTE SAMPLING
On 13 April 2016, START-3 collected four liquid waste samples (three normal samples and one
duplicate sample) from two on-site totes and one tank labeled as a “rinse water tank”. The
samples were collected to determine if the liquid contained hazardous substances. Sample IDs
assigned to the liquid waste samples includes: LPW01-AQ, LPW02-AQ, LPW02 (duplicate)
and LPW03-AQ. The liquid samples were collected using dedicated Coliwassa samplers to
collect representative samples of liquid waste. Liquid samples collected using the Coliwassa
sampler were immediately transferred into pre-cleaned glass containers with a Teflon-lined lid.
The liquid waste samples were stored in a cooler on ice and separate from the soil samples to
maintain sample integrity.
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4 ANALYTICAL METHODOLOGY
TestAmerica Laboratories in Houston, Texas conducted sample analyses, and data validation
was performed by the EPA Team as part of the TDD requirements. These tasks were conducted
in accordance with the WESTON Quality Assurance Program, and the EPA Team QASP
prepared under TDD No. 5/WESTON-042-16-004.
A standard data management system that includes using bound field logbook, site photographs,
sample management and tracking procedures, document control, and inventory procedures for
the laboratory data was utilized. SCRIBE software was utilized to manage and track sample
information for samples submitted to the participating laboratories.
Information regarding laboratory analyses and data validation is presented in the following
subsections.
4.1 SOIL SAMPLE ANALYSES
START-3 submitted a total of 36 soil samples for the following parameters:
TAL Metals by Method 6010B
Mercury by Method 7471A
Hexavalent Chromium [Cr(VI)] by Method SW‐846 7196A
4.2 LIQUID WASTE SAMPLE ANALYSES
Four liquid waste samples collected as part of this investigation were analyzed for the following
parameters:
TAL Metals by Method 6010B
Mercury by Method 7471A
Hexavalent Chromium [Cr(VI)] by Method SW‐846 7196A
Corrosivity (pH) Reactivity by Method 9045C
Cyanide (Reactivity) by Method 9012
Sulfide (Reactivity) by Method 9034.
TestAmerica Laboratories reported the analytical results in data packages meeting EPA Team
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requirements for importing and managing in SCRIBE. The laboratory documentation in these
data packages includes records of instrument readings, calculations, calibrations, and quality
assurance checks.
Appendix D includes the analytical data packages submitted by TestAmerica Laboratories.
4.3 DATA VALIDATION
The EPA Team performed data review and validation in accordance with EPA National
Functional Guidelines for Inorganic Superfund Data Review, August 2014. The data packages
were reviewed to verify they met the technical requirements and Quality Assurance (QA)
guidelines established for the respective analytical methods. The following list includes the items
evaluated for each laboratory sample delivery group (as applicable):
The completeness of the laboratory reports, verifying that all required components of the
reports were present and that the samples indicated on the accompanying chain-of-
custodies were addressed in the reports.
The sample receipt temperature was reviewed to verify the cooler temperature was
within acceptable range.
Holding times were reviewed to verify the samples were extracted and/or analyzed
within the required holding time.
The case narrative was reviewed for any noted sample receipt, sample preservation,
and/or analytical exceptions (instrument performance checks, initial calibration, initial
and continuing calibration verification checks, etc.).
Laboratory blanks were reviewed to determine whether laboratory contamination was
present.
Internal standards were reviewed to verify the recoveries were within the acceptable
range.
Laboratory control samples and/or laboratory control sample duplicates were reviewed
to verify the accuracy of the method.
Matrix spike/matrix spike duplicate samples were reviewed to determine whether matrix
interference was present and to determine if laboratory precision was within the
acceptable range.
Serial dilution samples were reviewed to verify that the percent difference was within
the acceptance criteria.
Field duplicates were reviewed to verify that field precision was within the acceptable
range.
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Reporting limits (Method Detection Limit [MDL], Limit of Determination [LOD], and
Limit of Quantitation [LOQ]) were reviewed to confirm they were adjusted to reflect
dilution factors, where applicable.
Sample results were reviewed to confirm that the detected concentration was within the
instrument calibration range. If the concentration exceeded the instrument calibration
range, the data were reviewed to determine if the sample was reanalyzed at a secondary
dilution.
The EPA Team reviewed the analytical results to verify that the data were acceptable for their
intended use in meeting the objectives of the project. The analytical results for the samples
collected for this project are acceptable for use with qualifiers assigned during validation. Data
validation reports are included in Appendix E.
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5 SUMMARY OF ANALYTICAL RESULTS
Soil and liquid waste sample analytical information is presented in the following subsections.
5.1 SOIL SAMPLES RESULTS
During field assessment activities, a total of 36 soil samples (30 composite samples and six grab
samples) including duplicate samples were collected and analyzed to determine nature and extent
of hazardous substances in soil. A review of the soil analytical results indicates that two
prevalent hazardous substances, hexavalent chromium and lead, were detected at levels
exceeding EPA RSLs criteria (Industrial Soil [THQ = 1.0], May 2016). Mercury was detected in
several soil samples above instrument detection limits but only Grid C2 exceeded the EPA RSL
criteria. A summary of soil analytical results is included in Table 5-1. Figure 4-1 illustrates
sample grids that exceeded for either hexavalent chromium, lead, and/or mercury. Individual
exceedance grid maps for hexavalent chromium, lead, and mercury have been prepared as
Figures 4-2 through 4-4.
A total of 30 composite soil samples (29 normal samples and 1 duplicate) were collected from a
grid system established around the footprint of the facility. Hexavalent chromium was detected
in 17 grids above the EPA RLS of 6.3 mg/Kg (Figure 4-2). Hexavalent chromium ranged in
concentration from non-detect 2.24 U (Grid A1) to 5,620 mg/Kg (Grid G7). The lowest detected
levels of hexavalent chromium was reported at a concentration of 167 mg/Kg (Grid E7).
As shown in Figure 4-3, lead was detected in five composite soil samples above the EPA RSL of
800 mg/Kg in Grids C2 (1,250 mg/Kg), D6 (1,810 mg/Kg), E7 (1,470 mg/Kg), F7 (5,400
mg/Kg), G5 (1,950 mg/Kg), and G7 (4,660 mg/kg). Lead concentrations raged from 28.9 mg/Kg
to as high as 5,400 mg/Kg (F7).
Mercury was detected at low levels in a number of girds across the site but only one grid (C2 –
113 mg/kg) exceeded the EPA RSL of 46 mg/Kg (Figure 4-4).
Four grab soil samples plus one field duplicate sample were collected from grids E6, F7, D5, E2,
and G3 to determine concentrations of hazardous constituents in soil at locations immediately
adjacent to the facility building. The IDs assigned to the grab soil samples included: LPW01-E6,
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LPW01-E6 (duplicate), LPW02-F7, LPW03-D5, LPW04-E2, and LPW05-G3. Hexavalent
chromium was non-detect (2.72 U mg/Kg) at Grid E2 (Sample ID: LPW04-E2), a sample point
immediately located along the north side of the facility. Grab sample LPW03-D5 (Grid D5) was
taken from the southern side of the facility and reported hexavalent chromium at a concentration
of 54.5 mg/Kg above the EPA RSL of 6.3 mg/Kg. Along the east side of the building, one grab
sample was collected (ID LPW05-G3) in Grid G3 and reported hexavalent chromium at a
concentration of 267 mg/Kg. LPW01-E6, collected from Grid E6, reported hexavalent
chromium at a concentration of 2,130 mg/Kg. Sample LPW02-F7 (Grid F7) reported hexavalent
chromium at a concentration of 130 mg/Kg.
5.2 LIQUID WASTE SAMPLE RESULTS
During field activities on 13 April 2016, four liquid waste samples (including three normal
samples and one duplicate sample) were collected to confirm the presence of hazardous
substances. A summary of liquid waste sample results is included in Table 5-2. The four liquid
waste samples are hazardous waste based on the characteristic of corrosivity with pH less than 2
according to SW-846 Method 9040C. LPW01 and LPW02 reported pH at 0.85 and 0.6,
respectively. LPW03 reported pH at 2.15. Total chromium ranged from 105,000 mg/Kg
(LPW01) to 296,000 mg/Kg (LPW02).
5.3 AIR MONITORING RESULTS
START-3 conducted air monitoring for acid gas, mercury vapors, and VOCs during the
preliminary site visit and throughout the soil and liquid waste sampling activities. No readings
above instrument detection levels were reported.