UNITED STATES DEPARTMENT OF ENERGY … Section...1 Jon J. Connor and Hansford T. Shacklette,...

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UNITED STATES DEPARTMENT OF ENERGY KANSAS CITY PLANT

KANSAS CITY, MISSOURI

Acid Pad Closure

• All waste was previously removed and managed according to applicable regulations. • The concrete floor, diking, and sump were inspected for signs of failure, leakage, and visible

contamination. Photographs of the lot are included. • The surface was washed and rinsed. The rinsate was treated at the Industrial Wastewater

Pretreatment Facility (IWPF). Concrete Surface Analyses • Thirteen (13) concrete chip samples were obtained from the surface of the lot. Each chip

sample characterized an approximate 400 square foot area. In addition, a sample was collected from the sump area. See the attached Figure 1 for chip sample grid locations. Each sample was analyzed for constituents identified in the Closure Plan.

• Chip sample “total” analytical results detected cadmium, chromium, nickel and silver while

barium, cadmium, chromium, and silver were detected by TCLP analysis. The type and concentration of these trace metals are not believed to be derived from operation of the Acid Pad as they are commonly found in cement as supported by Attachment I, An Analysis of Selected Trace Metals in Cement and Kiln Dust, by the Portland Cement Association.

Total and amenable cyanide were also detected but at levels well below regulatory limits.

• Table 1 shows each parameter detected along with its maximum concentration. All data

from closure sampling is attached. Subsurface Soil Investigation • Thirteen (13) soil borings were sampled each covering approximately 400 square feet. One

additional boring was placed in the sump. Figure 2 shows the locations of soil borings. Two samples were collected from each boring; one at a depth of one foot and one at a depth of five feet. Each sample was analyzed for constituents identified in the Closure Plan.

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Acid PadAlkaline PadGrating/sump

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DrawingTitle:

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RCRA Lot Closure

Figure 1: Location of Acid Pad Concrete Chip Samples

01/18/2013

2 Acid Pad

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Table 1

Maximum Concentrations of Compounds Detected In Acid Pad Concrete Chip Samples

CONTAMINANT MAXIMUM

CONCENTRATION (mg/kg)

(mg/L) – TCLP Barium (TCLP) 0.710

Cadmium (TCLP) 0.00804 Chromium (TCLP) 0.024

Silver (TCLP) 0.0131 Cadmium 0.909 Chromium 94.0

Nickel 24.8 Lead 59.2 Silver 7.51

Total cyanide 3.7 Amenable Cyanide 3.5

Reactive Sulfide 57.6

• Analytical results indicate trace metals are present in each sample (Table 2). Trace metals exist in soil based on previous soil sampling performed at the Kansas City Plant, supported by Attachment II, Updated Background Concentrations of Selected Elements in Unconsolidated Surficial Materials at the U. S. Department of Energy Kansas City Facility, prepared by Oak Ridge National Laboratory. The average background and threshold concentrations at the Kansas City Plant are summarized on page 27 of Attachment II. Silver values are not included in the attachment, however, the presence and concentration of this constituent is consistent with native uncontaminated soils1. In addition, TCLP analysis of Acid Pad soil sampling parameters and analysis of total and amendable cyanide indicate that they are all well below regulatory levels which would render them hazardous.

Determination of Rate and Extent 1 Jon J. Connor and Hansford T. Shacklette, Background Geochemistry of Some Rocks, Soils, Plants, and Vegetables in the Conterminous United States, Statistical Studies in Field Geochemistry (United States Government Printing Office, Washington: 1975), F30, F132.

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• Based on the fact that no compounds were detected in soil above Kansas City Plant soil background concentrations or were not over levels indicative of native soil or were detected at levels well below regulatory limits, no determination of rate and extent of contamination is recommended. Additional closure activities are not recommended.

Table 2 Maximum Concentrations of Compounds Detected In

Acid Pad Soil Samples

CONTAMINANT MAXIMUM CONCENTRATION

(mg/kg) (mg/L) – TCLP

Barium (TCLP) 2.53 Silver (TCLP) 0.0178 Chromium (TCLP) 0.0076 Cadmium 0.584 Chromium 20.4 Nickel 37.8 Silver 17.2 Lead 42.4 Cyanide (total) 2.1 Cyanide (amenable) 2.1

Acid Pad

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DrawingTitle:

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RCRA Lot Closure

Figure 2: Location of Acid Pad Soil Samples

01/21/2013

5 Acid Pad

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Demolition Lot (Demo Lot) Closure

• All waste was previously removed and managed as RCRA and/or TSCA waste. • The concrete floor, diking, and sump were inspected for signs of failure, leakage, and visible

contamination. Weathering (flaking) of concrete was noted around the outside Demo Lot sump. No other observations were noted. This area of weathering was specifically sampled as a part of closure concrete chip sampling. Pictures of the lot are included.

• The surface of the lot was washed and rinsed. The rinsate was managed in accordance with

applicable regulations. Concrete Surface Analyses • Thirty-one (31) concrete chip samples were obtained from the surface of the lot (Figure 1).

Each chip sample characterized an approximate 400 square foot area. In addition, a sample was collected from within sumps located in both the inside (covered) and outside (uncovered) portion of the lot. Each sample was analyzed for constituents identified in the Closure Plan. A table denoting the maximum concentration of all compounds detected is provided as Table 1. Organic Compounds Site specific clean up standards for organic compounds are provided in Table 1. These standards are based on the soil clean up standards published in the EPA Final Decision Response To Comments for the RCRA Multi-Site Corrective Measure Study (CMS) dated July 15, 1998. These are site specific, health based clean up standards selected by EPA for the KCP. 2-butanone and 4-methylphenol, however, did not have clean up standards established as a part of this CMS. Woodward Clyde Federal Services, who along with EPA derived the original clean up standards, established a health based soil clean up standard for 2-butanone and 4-methylphenol utilizing the calculations and assumptions used in the Multi-Site CMS. Additional calculations for the same compound utilizing the soil saturation concentration methodology employed by EPA were also made by Woodward Clyde. The lowest of the two calculated values (the “Health Based Clean Up Goal”) was chosen as the site specific clean up standard for concrete included in Table 1. Use of soil clean up standards for concrete is ultra conservative as it assumes ingestion of the concrete. The specific calculations are provided as Attachment II to this certification.

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• PCB’s were detected in many areas of the lot. Of the 20 grids sampled from the inside Demo Lot, all but 4 had PCBs less than 6 mg/kg with all but one grid detecting PCBs at detectable concentrations. Of 13 grids sampled on the outside Demo Lot (including the sump) no PCB’s over 1 mg/kg were detected. No documented spills after 1987 were found upon review of historical spill reports and record files. Other compounds frequently detected included xylene in 17 of the 33 grids, 2-butanone in 20 of the 33 grids and ethylbenzene in 10 of 33 grids sampled. Trace Metals

• Seven trace metals were detected from TCLP analysis in Demo Lot concrete sampling. They included chromium, barium, lead, silver, arsenic, cadmium and selenium up to the concentrations shown in Table 1. Chromium, nickel and lead were also detected from total analysis. These compounds were compared to levels for concrete analyzed by total and TCLP analysis in the document entitled, An Analysis of Selected Trace Metals in Cement and Kiln Dust, by the Portland Cement Association (PCA) provided as Attachment I. All trace metal results with the exception of TCLP levels for lead (144µg/L), arsenic (216µg/L) and selenium (242µg/L) were within the range noted in the PCA document. However, these TCLP levels are well below the 5,000µg/L, standard for lead and arsenic and the 1,000µg/L level for selenium which would render the material hazardous under RCRA.

The PCA document analyzes only the composition of cement, a component of concrete, whereas surface analysis for contamination performed as a part of the RCRA closure sampled and analyzed concrete which, in addition to cement, contains water, sand and gravel.

• An exposure assessment was performed as a result of the detections of trace metals over that found in the PCA document and is provided as Attachment III. This assessment concluded that under current and foreseeable future scenarios no significant exposure is anticipated and no further action is recommended.

Conclusion

• No further concrete sampling is recommended as a result of conclusions for trace metals reached in the exposure assessment and the fact that no organic compounds were detected at concentrations above site specific clean up standards.

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RCRA Lot Closure

Figure 1: Location of Demo Lot Concrete Chip Samples

01/18/2013

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Table 1

Maximum Concentrations and Clean Up Standards for Concrete Chip Samples Demolition Lot

CONSTITUENT MAXIMUM CONCENTRATION

(µg/kg) (µg/L) – TCLP

SOIL CLEAN UP STANDARDS

(µg/kg)

2-BUTANONE 110,000 (sump) 15,228,000 XYLENE 250 300,000 TOLUENE 140 (sump) 635,000 ETHYLBENZENE 40 283,000 ACETONE 73 (sump) 4.1235E+07 METHYLENE CHLORIDE

33 (sump) 5.11E+05

PCB (1260) 140,000 172,000 4-METHYLPHENOL 840 4,736,000 CHROMIUM (TCLP) 383 BARIUM (TCLP) 1350 LEAD (TCLP) 144 SILVER (TCLP) 40.8 ARSENIC (TCLP) 216 CADMIUM (TCLP) 8.54 SELENIUM (TCLP) 242 CHROMIUM (total) 39,900 NICKEL (total) 9,470 CYANIDE (total) 2,200 CYANIDE (amenable) 2,200 LEAD (total) 14,200

Subsurface Soil Investigation • Twenty nine (29) soil borings were sampled as a part of closure activities (Figure 2). Each

covered approximately 400 square feet. One additional boring was placed in each of the two sumps located in the inside (covered) and outside (uncovered) portion of the Demo Lot as sample numbers 30 and 31. Two samples were collected from each boring; one at a depth of one foot and one at a depth of five feet. Each sample was analyzed for constituents identified in the Closure Plan.

• Table 2 lists the compounds detected, the maximum concentration detected and the

corresponding health based site specific clean up levels. No compounds detected were over the prescribed clean up standards. A number of compounds were detected, the most prevalent of which was 2-butanone which was detected in 12 of the 31 grids sampled. TCE and acetone were detected in five of the 31 grids sampled with all remaining constituents

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detected in less than five grid areas each. Soil below sumps in both inside and outside portions of the lot were below detection limits for all compounds sampled.

• Analytical results indicate trace metals are present in soil samples (Table 2). Trace metals

exist in soil based on previous soil sampling performed at the Kansas City Plant, supported by Attachment II, Updated Background Concentrations of Selected Elements in Unconsolidated Surficial Materials at the U. S. Department of Energy Kansas City Facility, prepared by Oak Ridge National Laboratory. The average background and threshold concentrations at the Kansas City Plant are summarized on page 27 of Attachment II. With the exception of a single cadmium result in grid 3 at 1 foot at 6,200 µg/kg all soil samples were within KCP background ranges. TCLP analysis for cadmium from this same sample detected the trace metal at 13.3 µg/L far below the 1,000 µg/L level which would render the material hazardous under RCRA. This single detection is considered an outlier and when viewed with its corresponding TCLP result suggests that it is not present in a leachable form.

TCLP analysis of all other Demo Lot soil sampling parameters and analysis of total and amendable cyanide indicate that they are all well below regulatory levels which would render them hazardous.

Table 2 Maximum Concentrations and Clean up Standards for Soil Samples Demolition Lot

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SOIL CLEAN UP STANDARDS

(µg/kg)

2-BUTANONE 260 @1 ft. 15,228,000 XYLENE 46 @ 1 ft. 300,000 TOLUENE 22 @ 5 ft. 635,000 ETHYLBENZENE 12 @ 5 ft. 283,000 Tetrachloroethene 19 @ 5 ft. (1 hit) 149,000 ACETONE 220 @ 1 ft. 4.1235E+07 TCE 25 @ 5 ft. 135,000 METHYLENE CHLORIDE

11 @ 1 ft. 5.11E+05

PCB’s (1242 & 1254)

583 @ 1 ft. 1.72E+05

4-METHYL–2-PENTANONE

450 @ 1 ft. 585,000

CHROMIUM (TCLP)

18.7

BARIUM (TCLP) 2270 MERCURY (TCLP) 41.4 CADMIUM (TCLP) 50.4 SELENIUM (TCLP) 468 SILVER (TCLP) 7.86 CHROMIUM (total) 24,500 LEAD (total) 18,100 NICKEL (total) 44,700 CADMIUM (total) 6,200 CYANIDE (total) 1,200

Determination of Rate and Extent • All organic compounds detected in Demolition Lot soil borings were below site specific

clean up standards. With the exception of a single soil sample no analytes were detected in soil borings above Kansas City Plant soil background concentrations. The single detection of cadmium is considered a sampling outlier and when evaluated with its corresponding TCLP result is not present in a mobile form. For these reasons additional closure activities are not recommended.

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RCRA Lot Closure

Figure 2: Location of Demo Lot Soil Samples

01/21/2013

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DemoLot

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L-Lot Closure

• The concrete floor, diking, and sump were inspected for signs of failure, leakage, and visible

contamination. No observations were noted. • The surface of the lot was washed and rinsed. The rinsate was managed according to

applicable regulations. Concrete Surface Analyses • Twenty four (24) concrete chip samples were obtained from the surface of the lot (Figure 1).

Each chip sample characterized an approximate 400 square foot area. In addition, a sample was collected from sumps located in both the northwest and northeast portions of the lot as sample numbers 25 and 26. Each sample was analyzed for constituents identified in the Closure Plan.

The maximum concentration of all compounds detected along with corresponding site specific clean up standards are provided as Table 1. These standards are based on those published in the EPA Final Decision Response to Comments for the RCRA Multi-Site Corrective Measure Study (CMS) dated July 15, 1998. These are site specific, health based clean up standards selected by EPA for the KCP. 2-butanone, however, did not have a clean up standard established as a part of this CMS. Woodward Clyde Federal Services, who along with EPA derived the original clean up standards, established a health based soil clean up standard for 2-butanone utilizing the same calculations and assumptions used in the Multi-Site CMS. Additional calculations for the same compound utilizing the soil saturation concentration methodology employed by EPA were also made. The lowest of the two calculated values (the “Health Based Clean Up Goal”) was chosen as the site specific clean up standard for concrete included in Table 1. Use of soil clean up standards for concrete is ultra conservative as it assumes ingestion of the concrete. The specific calculations are provided as Attachment 1 to this certification.

• Clean up standards for Total Petroleum Hydrocarbons (TPH) consisting of TPH gas (gasoline

range) and Total Extractable Hydrocarbon fractions were exceeded in 20 of 24 grids sampled (all grids except 9-12). TPH clean up standards were not exceeded in the two sumps. As shown in Table 1, only TPH clean up standards were exceeded as a result of L-lot closure concrete sampling.

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RCRA Lot Closure

Figure 1: Location of L Lot Concrete Chip Samples

01/16/2013

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Table 1 Maximum Concentrations of Contaminants found in L-Lot Concrete Chip Samples

CONTAMINANT MAXIMUM

CONCENTRATION (µg/kg)

CLEAN UP STANDARD

(µg/kg) Soil

Gasoline (TPH light)

84,000 (sump) 500,000

Motor Oil TPH (heavy)

15,000,000 500,000

Toluene 31 635,000 Xylene 1,100 300,000 Ethylbenzene 240 283,000 Tetrachloroethene 22 149,000 Methylene chloride 5 511,000 2-Butanone 5,300 15,228,000 • The twenty TPH affected grids were scarified and re-analyzed for total petroleum

hydrocarbons. Fifteen of the twenty affected grids were found to be below site specific clean up levels as shown in Table 2 . Waste generated from the scarification operation was disposed of according to applicable regulations. The five grids which remained above the 500 mg/kg site specific clean up standard were further scarified and resampled and were all found to be below clean up criteria (Table 2). Based upon the fact that all affected grids were scarified to levels below site specific health based clean up standards, no further concrete clean up activity is recommended.

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Tabl e 2

Gr i d Speci f i c TPH Concent r at i ons i n t he L- Lot Concr et e Bef or e and Af t er Scar i f i cat i on

GRID NUMBER

(see Figure 1)

INITIAL RESULT (mg/kg)

RESULT AFTER FIRST ROUND OF SCARIFICATION

(mg/kg)

RESULT AFTER SECOND ROUND

OF SCARIFICATION (mg/kg)

1 1,400 110 2 520 ND 3 4,000 83 4 630 ND 5 3,205.7 39 6 2,108.2 73 7 1,000 ND 8 2,106.5 49 13 15,020 1300 430 14 3,114 816.2 ND 15 4,835 550 ND 16 2,745 72.5 17 3,722 83 18 2,707 ND 19 1,937 80 20 2,941 260 21 3,316 760 ND 22 2,218 245.6 23 4,815 170 24 11,040 827.2 ND

Subsur f ace Soi l I nvest i gat i on • Twenty four (24) soil borings were sampled as a part of closure activities (Figure 2). Each

covered approximately 400 square feet. One additional boring was placed in each of the two sumps located in the northwest and northeast corners of the lot Two samples were collected from each boring; one at a depth of one foot and one at a depth of five feet. Each sample was analyzed for constituents identified in the Closure Plan.


corresponding health based site specific clean up levels for L-lot soil samples. No compounds detected were over the prescribed health based clean up standards. The trace

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metals cadmium, lead and chromium were detected by TCLP analysis (total metals analysis was not performed). Maximum levels detected for the three trace metals were well below that which would render the waste hazardous under RCRA.

• A number of organic compounds were detected, the most prevalent of which was 2-butanone

which was detected in 16 of the 24 borings sampled.

Tabl e 3 Maxi mum Concent r at i on and Cl ean up St andar ds For Soi l Sampl es

L- Lot

CONTAMINANT MAXIMUM CONCENTR

ATION (µg/kg) (µg/L) – TCLP

CLEAN UP STANDARD

(µg/kg) Soil

2-BUTANONE 450 @ 1 & 5 ft.

15,228,000

XYLENE 33 @ 1 ft. 300,000 TRICHLOROETHYLENE 11 @ 1ft. 135,000 TOLUENE 6.7 @ 5 ft. 635,000 ETHYLBENZENE 6.3 @ 1 ft. 283,000 GASOLINE 32,000 @ 1 ft. 500,000 DIESEL 200,000 @ 1

ft. 500,000

CADMIUM (TCLP) 9.95 @ 1 ft. LEAD (TCLP) 55.3 @ 5 ft. CHROMIUM (TCLP) 14 @ 5ft. Det er mi nat i on of Rat e and Ext ent Contamination detected in L-Lot soil borings were below site specific clean up standards. For this reason no determination of rate and extent is necessary and no further closure activities are recommended.

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RCRA Lot Closure

Figure 2: Location of L Lot Soil Samples

01/21/2013

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L - Lot

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Tank Farm Container Storage Lot Closure

• All waste was previously removed and managed as RCRA waste. • The concrete floor, diking, and sump were inspected for signs of failure, leakage, and visible

contamination. None were noted. • The surface of the lot was washed and rinsed. The rinsate was treated in accordance with

applicable regulations. Concrete Surface Analyses • Twenty-six (26) concrete chip samples were obtained from the surface of the lot. Twenty

three (23) chip samples each characterized an approximate 400 square foot area (Figure 1). In addition, one concrete chip sample was collected from the base of the surface runoff containment sump (grid sample 23), the base of the containment trench (grid sample 24) and from the containment sump in the PCB fill station (grid sample 26). Each sample was analyzed for constituents identified in the Closure Plan.

• A table denoting the maximum concentration of all compounds detected along with site

specific clean up standards for the organic compounds is provided as Table 1. These standards are based on those published in the EPA Final Decision Response to Comments for the RCRA Multi-Site Corrective Measure Study (CMS) dated July 15 1998. These are site specific, health based clean up standards selected by EPA for the KCP. 2-butanone and 4-methyl 2-pentanone, however, did not have clean up standards established as a part of this CMS. Woodward Clyde Federal Services, who along with EPA derived the original clean up standards, established a health based soil clean up standard for 2-butanone and 4-methyl 2-pentanone utilizing the calculations and assumptions used in the Multi-Site CMS. Additional calculations for the same compounds utilizing the soil saturation concentration methodology employed by EPA were also made by Woodward Clyde. The lowest of the two calculated values (the “Health Based Clean Up Goal”) was chosen as the site specific clean up standard for concrete included in Table 1. Use of soil clean up standards for concrete is ultra conservative as it assumes ingestion of the concrete. The specific calculations are provided as Attachment II to this certification.

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RCRA Lot Closure

Figure 1: Location of Tank Farm Concrete Chip Samples

01/18/2013

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Tank Farm

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• As provided in the analytical data project narrative for the concrete chip samples recoveries for surrogates and matrix spike compounds in many cases were outside control limits. The results were adversely affected by interfering compounds including furfuryl alcohol. Reaction by-products resulting from reaction of the reagents in the analytical process with the chip samples (calcium hydroxide) adversely affected QC parameters by producing 4-hydroxy-4-methyl-2-pentanone from acetone.

• Thirteen of the 26 samples from the Tank Farm container storage area detected PCBs.

However, only sample 25 collected from the area known as the PCB fill station (i.e., the area where PCB waste was pumped from drums into the now closed PCB tank) exceeded site specific clean up standards.

This area was scarified to a depth of ½ inch. A sample from the treated grid was collected and analyzed for PCB’s and found to be below treatment standards. For this reason no further concrete sampling was performed. Table 2 lists PCB concentrations before and after scarification.

• Five trace metals were detected from TCLP analysis in Tank Farm Lot concrete sampling.

They included barium, chromium, silver, arsenic, and selenium up to the concentrations shown in Table 1. These trace metals were compared to levels for cement analyzed by total and TCLP analysis in the document entitled, An Analysis of Selected Trace Metals in Cement and Kiln Dust, by the Portland Cement Association (PCA) provided as Attachment I. All trace metal results with the exception of TCLP levels for arsenic (111 µg/L) and selenium (357 µg/L) were within the ranges noted in the PCA document. These TCLP levels are well below the 5,000 µg/L, standard for arsenic and the 1,000 µg/L level for selenium which would render the material hazardous under RCRA.

The PCA document analyzes only the composition of cement, a component of concrete, whereas surface analysis for contamination performed as a part of this RCRA closure sampled and analyzed concrete which, in addition to cement, contains rocks of varying size fractions.

• An exposure assessment was performed as a result of the detections of trace metals over that found in the PCA document and is provided as Attachment III. This assessment concluded that under current and foreseeable future scenarios no significant exposure is anticipated and no further action is recommended.

Conclusion • No further concrete sampling is recommended as a part of RCRA closure for the Tank Farm

for the following reasons: PCB concentrations in concrete which exceeded site specific

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health based clean up standards have been removed by scarification to levels below clean up standards; all other organic compounds are present in concrete at levels below site specific health based clean up standards; and the existence of low levels of trace metals in leach samples of concrete from the lot pose no significant exposure (or risk) based on current and reasonably likely future use scenarios.

Table 1 Maximum Concentrations and Clean Up Standards for Concrete Chip Samples

Tank Farm

CONTAMINANT MAXIMUM CONCENTRATION (µg/kg)

(µg/L) – TCLP

SOIL CLEAN UP STANDARD

(µg/kg) 2-BUTANONE 25,000 15,228,000 XYLENE 1,300 300,000 TOLUENE 66 635,000 ETHYLBENZENE 17,000 283,000 4-METHYL-2 PENTANONE

39,000 585,000

PCBs (1242 & 1260) 3.66E+06 1.72E+05 ACETONE 90 4.1235E+07 METHYLENE CHLORIDE 11 5.11E+05 TCE 9.1 1.35E+05 TCE (TCLP) 130 2-BUTANONE (TCLP) 1000 Cyanide (total) 1300.0 BARIUM (TCLP) 845 CHROMIUM (TCLP) 44.8 ARSENIC (TCLP) 111 SELENIUM (TCLP) 357 SILVER (TCLP) 16.5

Table 2 Grid Specific PCB Concentrations in Tank Farm Grid Exceeding PCB Clean up Standards GRID NUMBER INITIAL RESULT RESULT AFTER

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(µg/kg) SCARIFICATION (µg/kg) 25 3.66E+06 33 Subsurface Soil Investigation • Twenty three (23) soil borings were sampled as a part of closure activities (Figure 2). Each

covered approximately 400 square feet. Specific locations of borings within grids were guided by the location of underground utilities. One boring was placed in each of the two sumps noted as samples 18 and 23. Each sample was analyzed for constituents identified in the Closure Plan.


corresponding health based site specific clean up levels for organic compounds. No compounds detected were over the prescribed clean up standards. Of the compounds detected, the most prevalent was 2-butanone which was detected in 9 of the 23 grids with TCE detected in 4 of the 23 grids sampled. All other organic compounds were detected in less than four grids.

• Cyanide was detected from soil sampling at a maximum concentration of 1,900 µg/kg. This

is well below the 250,000 µg/kg level which would render the material hazardous under RCRA. A number of trace metals were also detected through TCLP analysis. The presence of these constituents is consistent with that of native soils1.

Table 3 Maximum Concentrations and Clean Up Standards for Soil

Tank Farm CONTAMINANT MAX. CLEAN UP STANDARD (µg/kg)

1 Jon J. Connor and Hansford T. Shacklette, Background Geochemistry of Some Rocks, Soils, Plants, and Vegetables in the Conterminous United States, Statistical Studies in Field Geochemistry (United States Government Printing Office, Washington: 1975), F30, F132.

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Soil

2-Butanone 95 15,228,000 PCB 310 1.72 E+05 TCE 21 1.35 E+05 Tetrachloroethene 15 149,000 4 methyl 2 pentanone

24 585,000

Xylene 8.8 300,000 Cyanide (total) 1,900 Cyanide (amenable) 1,900 Barium (TCLP) 2,140 Chromium (TCLP) 23.4 Selenium (TCLP) 530 Cadmium (TCLP) 11.4 Silver (TCLP) 7.59 Determination of Rate and Extent Organic contamination detected in Tank Farm container storage lot borings were well below site specific clean up standards. The presence of low level inorganic compounds is not inconsistent with that of native uncontaminated soils. The levels detected are well below that which would render the material hazardous under RCRA. For these reasons no determination of rate and extent is necessary and no further closure activities are recommended.

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RCRA Lot Closure

Figure 2: Location of Tank Farm Soil Samples

01/21/2013

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Tank Farm

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Test Cell 1 Closure


contamination. No observations were found. Photographs of the lot are included. • The surface was washed and rinsed. The rinsate was managed in accordance with applicable

regulations. Concrete Surface Analyses • Eight (8) concrete chip samples were obtained from the Test Cell, two of which were

collected from the wall (Figure 1). Each chip sample characterized an approximate 400 square foot area. Each sample was analyzed for constituents identified in the Closure Plan.

• Chip sample analytical results detected 2-butanone (methyl ethyl ketone (MEK)) in each of

the eight samples ranging from 26 to 44,000 µg/kg. Xylene and toluene were detected in two and one of the eight grids, respectively.

• Barium, chromium, selenium, silver and arsenic were detected through TCLP analysis. The

type and concentration of these trace metals found in Test Cell 1 concrete were compared to levels found in cement listed in the document entitled, An Analysis of Selected Trace Metals in Cement and Kiln Dust, by the Portland Cement Association (PCA) provided as Attachment I. The maximum TCLP levels for selenium and arsenic were 280 and 106 µg/L, respectively, which exceeded values for concrete listed in the PCA document. However these TCLP levels are well below the 1,000 and 5,000 µg/L levels which would render the material hazardous under RCRA. The PCA document analyzes only the composition of cement a component of concrete, whereas surface analysis for contamination performed as a part of the RCRA closure sampled and analyzed concrete which in addition to cement contains water, sand and gravel. An exposure assessment was performed as a result of these detections and is provided as Attachment III. This assessment concluded that under current and foreseeable future scenarios no significant exposure is anticipated and no further action is recommended.

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• Cyanide was detected at levels up to 13.5 mg/kg which is well below the 250 mg/kg level which would constitute reactive hazardous waste. Table 1 denotes the highest concentrations detected in any concrete chip sample.

• A table denoting the maximum concentration of all compounds detected along with site

specific clean up standards for the organic compounds is provided as Table 1. These standards are based on the soil clean up standards published in the EPA Final Decision /Response To Comments for the RCRA Multi-Site Corrective Measure Study (CMS) dated July 15, 1998. These are site specific, health based clean up standards selected by EPA for the KCP. 2-butanone, however, did not have clean up standards established as a part of this CMS. Woodward Clyde Federal Services, who along with EPA derived the original clean up standards, established a health based soil clean up standard for 2-butanone utilizing the calculations and assumptions used in the Multi-Site CMS. Additional calculations for the same compound utilizing the soil saturation concentration methodology employed by EPA were also made by Woodward Clyde. The lowest of the two calculated values (the “Health Based Clean Up Goal”) was chosen as the site specific clean up standard for concrete included in Table 1. Use of soil clean up standards for concrete is ultra conservative as it assumes ingestion of the concrete. The specific calculations are provided as Attachment II to this certification.

Table 1 Maximum Concentrations Detected In Test Cell 1 Chip Samples


CLEAN UP STANDARD

(µg/kg)

2-Butanone 44,000 µg/kg 15,228,000 Toluene 6 µg/kg 635,000 Xylene 27 µg/kg 300,000 Barium (TCLP) 716 µg/L Chromium (TCLP)

37.4 µg/L

Selenium (TCLP) 280 µg/L Silver (TCLP) 17.2 µg/L Arsenic (TCLP) 106 µg/L Cyanide (amenable)

7.7 mg/kg Non-corrosive

Cyanide (reactive) 1.98 mg/kg Non-reactive Cyanide (Total) 13.5 mg/kg

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• A project narrative is provided by the laboratory noting that recoveries for surrogates and matrix spike compounds in many samples were outside control limits due to large amounts of interfering compounds including furfuryl alcohol. In addition a sample for semivolatile analysis was not analyzed for TCLP semivolatiles because of a laboratory accident with the extracted sample vial.

• As shown in Table l no compounds were detected at concentrations above site specific

clean up standards. For this reason no further concrete sampling is recommended. Subsurface Soil Investigation • Two (2) soil borings were sampled at each end of the Test Cell (Figure 2). Two samples

were collected from each boring; one at a depth of one foot and one at a depth of five feet. Each sample was analyzed for constituents identified in the Closure Plan. No organic contaminants were detected in any of the soil samples. Barium, chromium and selenium were detected by TCLP analysis up to 1.71 mg/kg, 0.00741 mg/kg and 0.181 mg/kg respectively. These levels are all below RCRA characteristic waste criteria. The presence of these constituents is also consistent with native uncontaminated soils1.

Determination of Rate and Extent • No organic contamination was detected in soils while the levels of barium, chromium and

selenium detected by TCLP analysis are well below RCRA levels. These trace metals are also naturally present in native soils. For these reasons no further soil sampling or related closure activities are recommended.


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Test Cell 2 Closure

• All waste was previously removed and managed as RCRA waste. • The concrete floor, diking, and sump were inspected for signs of failure, leakage, and

visible contamination. No observations were found. Photographs of the lot are included.

• The surface was washed and rinsed. The rinsate was managed in accordance with

applicable regulations. Concrete Surface Analyses • Eight (8) concrete chip samples were obtained from the lot. Six samples were

collected from the floor with two samples collected from the wall (Figure 1). Each chip sample characterized an approximate 400 square foot area. Each sample was analyzed for constituents identified in the Closure Plan.

• Chip sample analytical results detected 2-butanone (methyl ethyl ketone (MEK)) in

each of the eight samples ranging from 110 to 48,000 µg/kg. Xylene and toluene were detected in eight and five of the eight grids, respectively. Ethylbenzene was detected in three of the eight.

• Barium and chromium were detected from TCLP analysis at 510 µg/L and 31.8 µg/L

respectively. The type and concentration of these trace metals are not believed to be derived from operation of Test Cell 3 as they are commonly found in cement as supported by Attachment I, An Analysis of Selected Trace Metals in Cement and Kiln Dust, by the Portland Cement Association.

• PCB’s were detected in seven of the eight grids sampled. PCB’s were added to the sample parameter list for Test Cell 2 as it was discovered through a historical records search that PCB’s were managed on the lot. PCB concrete chip sampling, therefore, occurred at a later date than sampling for all other compounds. Sampling locations were immediately adjacent to the original chip samples collected on February 26 and 27, 1998.

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• A table denoting the maximum concentration of all compounds detected in concrete chips along with site specific clean up standards for organic compounds is provided as Table 1. These clean up standards are based on the soil clean up standards published in the EPA Final Decision Response To Comments for the RCRA Multi-Site Corrective Measure Study (CMS) dated July 15, 1998. These are site specific, health based clean up standards selected by EPA for the KCP. 2-butanone, however, did not have clean up standards established as a part of this CMS. Woodward Clyde Federal Services, who along with EPA derived the original clean up standards, established a health based soil clean up standard for 2-butanone utilizing the calculations and assumptions used in the Multi-Site CMS. Additional calculations for the same compound utilizing the soil saturation concentration methodology employed by EPA were also made by Woodward Clyde. The lowest of the two calculated values (the “Health Based Clean Up Goal”) was chosen as the site specific clean up standard for concrete included in Table 1. Use of soil clean up standards for concrete is ultra conservative as it assumes ingestion of the concrete. The specific calculations are provided as Attachment II to this certification.

• As provided in the analytical data project narrative for the concrete chip samples

recoveries for surrogates and matrix spike compounds in many cases were outside control limits. The results were adversely affected by interfering compounds including furfuryl alcohol. Reaction by-products resulting from reaction of the reagents in the analytical process with the chip samples (calcium hydroxide) adversely affected QC parameters by producing 4-hydroxy-4-methyl-2-pentanone from acetone.

• As shown in Table l no organic compounds were detected at concentrations above

site specific clean up standards. TCLP values for inorganic compounds were all well below that which would render them hazardous under RCRA and were within the concentration range indicative of cement. For these reasons no further concrete sampling is recommended.

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Table 1

Maximum Contaminant Concentrations Detected in Test Cell 2 Concrete.

CONSTITUENT MAXIMUM


(µg/L) – TCLP

CLEAN UP STANDARDS

(µg/kg)

2-BUTANONE 48,000 15,228,000 XYLENE 51 300,000 TOLUENE 9.8

635,000

ETHYLBENZENE 9.2 283,000 PCB’s 1,740 172,000 BARIUM (TCLP) 510 CHROMIUM (TCLP)

31.8

Subsurface Soil Investigation • Two (2) soil borings were drilled at each end of the Test Cell (Figure 2). Two

samples were collected from each boring; one at a depth of one foot and one at a depth of five feet. Each sample was analyzed for constituents identified in the Closure Plan. Trichloroethylene was detected at 6.1 µg/kg at the five foot depth in the west end of the Test Cell.

Barium and selenium were detected by TCLP analysis in soil samples up to 1,340 µg/L and 148 µg/L respectively. The presence of these constituents is consistent with native uncontaminated soils1. Pursuant to approval from MDNR, no soil sampling for PCB’s was conducted on this lot since the highest PCB value in concrete was less than 2 mg/kg.


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Table 2 Maximum Concentrations Detected in Test Cell 2 Soil Samples

CONSTITUENT MAXIMUM


(µg/L) – TCLP

CLEAN UP STANDARDS

(µg/kg)

TCE 6.1 @ 5 ft. 135,000 BARIUM (TCLP) 1,340 SELENIUM (TCLP) 148

Determination of Rate and Extent • Trichloroethylene was detected in one soil sample at a five foot depth at 6.1 µg/kg.

This level is well below the 135,000 µg/kg site specific clean up standard. Barium and selenium were present at detectable levels from TCLP analysis. These levels were well below that which would render the soil hazardous under RCRA and were present at concentrations consistent with native soil. For these reasons, no determination of rate and extent is necessary and no further closure activities are recommended.

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Test Cell 3 Closure

• All waste was previously removed and managed as RCRA waste. • The concrete floor, diking, and sump were inspected for signs of failure, leakage, and

visible contamination. No observations were noted. Photographs of the lot are included.

• The surface was washed and rinsed. The rinsate was managed in accordance with

applicable regulations. Concrete Surface Analyses • Ten (10) concrete chip samples were obtained from the surface of the Test Cell on

January 9, 1998. Each chip sample characterized an approximate 400 square foot area. Sample grid locations are shown in Figure 1. Each sample was analyzed for constituents identified in the Closure Plan.

• Chip sample TCLP analytical results detected barium, chromium and silver up to 540

µg/L, 47.7 µg/L and 16.7µg/L, respectively. The type and concentration of these trace metals are not believed to be derived from operation of Test Cell 3 as they are commonly found in cement as supported by Attachment I, An Analysis of Selected Trace Metals in Cement and Kiln Dust, by the Portland Cement Association. Two detections of total cyanide up to 1.5 mg/kg were also noted from this sampling which is well below the 250 mg/kg level which would constitute reactive hazardous waste. Table 1 below denotes the highest concentrations detected in any chip sample.

Table 1 Maximum Concentrations Detected in Test Cell 3 Chip Samples


(µg/kg) (µg/L) - TCLP

Barium (TCLP) 540 Chromium (TCLP) 47.7 Silver (TCLP) 16.7 Cyanide 1500

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• The constituents in Table 1 are either within the concentration range indicative of cement and/or are below levels which would render the material hazardous under RCRA. For these reasons, no further sampling of concrete is recommended.

Subsurface Soil Investigation • Two (2) soil borings were drilled and sampled through the base of Test Cell 3 at each

end (Figure 2). Two samples were collected from each boring; one at a depth of one foot and one at a depth of five feet into native soil. Each sample was analyzed for constituents identified in the Closure Plan.

• Analytical results from TCLP analysis indicate trace metals are present in each

sample. Table 2 lists the maximum concentrations found. Barium, chromium and selenium were the only compounds noted from sampling. The presence of these constituents is consistent with native uncontaminated soils1. The concentrations of these parameters in soil are well below that which would render it a hazardous waste under RCRA.

Table 2 Maximum Concentrations Detected in Test Cell 3 Soil

CONTAMINANT MAXIMUM CONCENTRATION (µg/L)

Barium (TCLP) 993 Chromium (TCLP) 8.57 Selenium (TCLP) 405

Determination of Rate and Extent • The three parameters found in Test Cell 3 soil are present in native soils and their

concentrations are well below that which would render them hazardous under RCRA. For these reasons no determination of rate and extent of contamination is necessary.


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Test Cell 4 Closure (Amended April 1999)

• All waste was previously removed and managed as RCRA waste. • The concrete floor was inspected for signs of failure, leakage, and visible

contamination. No observations were found. Photographs of the lot are included. • The surface was washed and rinsed. The rinsate was managed in accordance with

applicable regulations.

Concrete Surface Analyses • Ten (10) concrete chip samples were obtained from the floor of the Test Cell on

January 9, 1998 (Figure 1). Each chip sample characterized an approximate 400 square foot area . Each sample was analyzed for constituents identified in the Closure Plan.

• Ethylbenzene and xylene were detected at elevated concentrations in each of the ten

chip samples. PCB’s up to 400 µg/kg were detected in four of the ten chip samples. Compounds detected along with their maximum concentrations are provided in Table 1.

• The consistently elevated levels of ethylbenzene and xylene in each of the 10

concrete floor samples and previous concrete sampling results from the Red-X RCRA hazardous waste storage lot suggested that the floor coating was the source of these compounds. Ratios of ethylbenzene to xylene in all Test Cell 4 concrete chip samples were very consistent averaging between 19 and 20%. To further assist in verifying this possibility, two additional samples from the wall of the Test Cell not covered by the coating were sampled on February 2, 1998. Ethylbenzene and xylene were not detected in these two samples further indicating the floor coating as the source of ethylbenzene and xylene in the concrete floor samples (Table 2). A sample of surface coating was collected from the test cell on February 2, 1998. Results from this sample detected ethylbenzene and xylene but at lower levels than found in the previous 10 samples (Table 2). Upon follow up investigation of the location of this coating sample, it was found that the coating in this area of Test Cell 4 was lighter in color than that collected in the 10 original samples. Ethylbenzene to xylene ratios for this light colored sample averaged 15.3% as opposed to the 19-20 % for other

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Table 1 Maximum Concentrations Detected in Test Cell 4

Chip Samples


(µg/kg)

CLEAN UP STANDARDS

(µg/kg) PCB 1260 & 1242 400 1.72E+05 XYLENE 4,600,000 300,000 ETHYLBENZENE 900,000 283,000

Table 2

Test Cell 4 Original Closure Sampling (Dark) µg/kg Constituent Conc. Range Detection Limit Ethylbenzene/Xylene Ratio (All 8 samples) Ethylbenzene 300,000-900,000 12,000/31,000 19-20% Xylene 1,600,000-4,600,000 12,000/31,000 -----------------------------------------------------------------------------------------------------------

Test Cell 4 Wall Samples (no coating) µg/kg Constituent Conc. Range Detection limit Ethylbenzene/Xylene Ratio (2 samples) Ethylbenzene ND 5 NA Xylene ND 5 ------------------------------------------------------------------------------------------------------------

Test Cell 4 Coating Sample (Light color) µg/kg Constituent Conc. Range Detection Limit Ethylbenzene/Xylene Ratio (1 sample) Ethylbenzene 66,000 2,900 15.3% Xylene 430,000 7,400 ----------------------------------------------------------------------------------------------------------

Test Cell 3 (Light) µg/kg (No Requirement to Test for VOC’s) Constituent Conc. Range Detection Limit Ethylbenzene/Xylene Ratio (2 samples) Ethylbenzene 67-69 50

14-16% Xylene 420-500 130 ----------------------------------------------------------------------------------------------------------

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samples in the test cell. It was then discovered that adjacent Test Cell 3, (which was not required to be sampled for VOCs) was also coated with this light colored coating.

Two concrete chip samples were then collected from the floor of Test Cell 3 on February 2, 1998. Results of this sampling detected the lower level of ethylbenzene and xylene with a compound ratio of 14 to 16% like that of the light colored coating in Test Cell 4 (Table 2). These results further substantiate the surface coating as the source of elevated detection of ethylbenzene and xylene.

• As part of similar problems of elevated levels of ethylbenzene and xylene

encountered during closure of the Red-X lot, two separate hardened tile samples of the coating product called “Overkote Plus” believed to have been used to coat the Red-X lot and some of the Test Cells were obtained from the vendor and analyzed for benzene, toluene, ethylbenzene and xylene (BTEX). The results, displayed below in µg/kg, show that ethylbenzene and xylene were present in the samples at elevated concentrations with xylene as the predominant compound (Table 3).

Table 3

Overkote Plus Analytical Results Coating

Sample No. Benzene Toluene Ethylbenzene Xylene

1 ND 1,000 26,000 93,000 2 ND ND 8,200 29,000

• Based on: 1) the ubiquitous nature of ethylbenzene and xylene in concrete chip

samples at Test Cell 4; 2) the similarity of ethylbenzene to xylene ratios between each chip sample, 3) the absence of ethylbenzene and xylene in two samples from Test Cell 4 which did not contain coating; 4) the similar compounds found in the coating samples and; 5) the detection of similar ratios of ethylbenzene and xylene at overall lower concentrations from light colored coating in Test Cells 4 and 3 all indicate that the coating in Test Cell 4 is the source of elevated levels of ethylbenzene and xylene in concrete chip samples from Test Cell 4.

• PCB’s were detected in four of the 10 grids sampled as a part of closure, up to a

maximum concentration of 400 µg/kg, well below the health based site specific clean up standards for closure. The PCB’s were derived from a 1993 spill of transformer oil. At that time the area was cleaned and decontaminated to less than 100µg/100cm3 and encapsulated. The location of PCB’s detected in Test Cell 4 closure sampling corresponds to the location of this spill.

Based upon the data collected and described above, the detection of ethylbenzene and xylene in concrete chip samples in Test Cell 4 resulted from the surface coating in the test cell and not from hazardous waste management activities. The detection of PCB’s in

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concrete chip samples in Test Cell 4 are below health based site specific clean up standards to be used for closure at the KCP. Due to the fact that sampling inside Test Cell 4 indicated that the protective floor and wall coatings contained ethylbenzene and xylene at concentrations above the established risk-based levels for industrial use, the floor coating was removed. The coating was a trowel-applied epoxy/sand mixture which had a minimum thickness of 1/4 inch. The lower two feet of the walls were coated with a fiber-reinforced epoxy material that was approximately 80 mils thick. The coatings were chipped off the concrete substrate using electric hammers with chisel bits. Workers wore Level C personal protective equipment. The debris was disposed of as TSCA-regulated PCB waste due to the wastes previously stored in the test cell. The floor of the Test Cell was then resampled in the same grid locations shown in Figure 1 for ethylbenzene and xylene on March 19, 1999. All results were below site clean up standards. For this reason no further closure activities for the concrete floor and wall are recommended. Subsurface Soil Investigation • Two (2) soil borings were sampled at each end of the Test Cell (Figure 2). Two

samples were collected from each boring; one at a depth of one foot and one at a depth of five feet into native soil. Each sample was analyzed for constituents identified in the Closure Plan. No compounds were detected.

Determination of Rate and Extent • As a result of the absence of contamination in soil samples from Test Cell 4 no

further closure activities are recommended.

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Test Cell 10 Closure

• All waste was previously removed and managed according to applicable regulations. • The concrete floor, diking, and sump were inspected for signs of failure, leakage, and visible

contamination. No observations were found. Photographs of the lot are included. • The surface was washed and rinsed. The rinsate was managed according to applicable

regulations. Concrete Surface Analyses • Two (2) concrete chip samples were obtained from the Test Cell (Figure 1). One sample

was collected from the floor of the test cell characterizing an approximate 400 square foot area . In addition, a sample was collected from the floor sump. Each sample was analyzed for constituents identified in the Closure Plan.

• Chip sample analytical results of total metals detected chromium, lead and nickel while

TCLP analysis detected barium, chromium, selenium, silver and mercury up to the concentrations shown in Table 1. The type and concentration of these compounds found in Test Cell 10 concrete were compared to levels found in cement in the document entitled An Analysis of Selected Trace Metals in Cement and Kiln Dust, by the Portland Cement Association (PCA) provided as Attachment I. The maximum TCLP levels for selenium and mercury were 249 µg/L and 57.3 µg/L, respectively, which exceeded values for concrete listed in the PCA document. However, these TCLP levels are well below the 1000µg/L and 200µg/L levels which would render the concrete hazardous under RCRA.

The PCA document analyzes only the composition of cement a component of concrete, whereas surface analysis for contamination performed as a part of the RCRA closure sampled and analyzed concrete which in addition to cement contains water, sand and gravel.

• An exposure assessment was performed as a result of these detections and is provided as

Attachment II. This assessment concluded that under current and foreseeable future scenarios no significant exposure is anticipated and no further action is recommended.

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Test Cell 10 Concrete Chip Samples

CONSTITUENT

MAXIMUM CONCENTRATION (mg/kg)

(µg/L) – TCLP Barium (TCLP) 257 Chromium (TCLP) 40.3 Selenium (TCLP) 249 Silver (TCLP) 10.6 Mercury (TCLP) 57.3 Lead 10.4 Chromium 11.2 Nickel 8.22

Subsurface Soil Investigation • Two (2) soil borings were sampled as a part of closure, one in the floor of the Test Cell and

one in the floor sump (Figure 2). Two samples were collected from each boring; one at a depth of one foot and one at a depth of five feet. Each sample was analyzed for constituents identified in the Closure Plan.

Analytical results indicate trace metals are present in each sample. Chromium, lead and nickel were detected as a part of total constituent analysis while barium, selenium and silver were detected as a part of TCLP analysis. Inorganic constituents exist in soil based on previous soil sampling performed at the Kansas City Plant, supported by Attachment III, Updated Background Concentrations of Selected Elements in Unconsolidated Surficial Materials at the U. S. Department of Energy Kansas City Facility, prepared by Oak Ridge National Laboratory. The average background and threshold concentrations at the Kansas City Plant are summarized on page 27 of Attachment III. Total analysis results for lead, chromium and nickel are all within KCP background ranges. TCLP results for barium, selenium and silver are well below values which would render the material hazardous under RCRA The presence of these constituents is consistent with native uncontaminated soils1.


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Test Cell 10 Soils

CONSTITUENT

MAXIMUM CONCENTRATION (µg/kg)

(µg/L) - TCLP Barium (TCLP) 2,430 Selenium (TCLP) 534 Silver (TCLP) 9.42 Chromium 20.7 Lead 17.9 Nickel 21

Determination of Rate and Extent • The levels from total analysis of lead nickel and chromium found in Test Cell 10 soils are

consistent with background concentrations of inorganic compounds at the KCP. TCLP concentrations for barium, selenium and silver from Test Cell 10 are well below RCRA levels and are naturally present in native soils. For these reasons no further soil sampling or related closure activities are recommended.

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Test Cell 11 Closure


contamination. No observations were found. Photographs of the lot are included. • The surface was washed and rinsed. The rinsate was managed in accordance with applicable

regulations. Concrete Surface Analyses • Two (2) concrete chip samples were obtained from the surface of the Test Cell. One sample

was collected from the floor while the other was collected in the containment sump (Figure 1). Each sample was analyzed for constituents identified in the Closure Plan.

4-methyl-2-pentanone, xylene, toluene, ethylbenzene and acetone were detected in both concrete chip samples up to the levels shown in Table 1. This table provides the maximum concentration of all compounds detected along with site specific clean up standards for the organic compounds. These standards are based on the soil clean up standards published in the EPA Final Decision Response to Comments for the RCRA Multi-Site Corrective Measure Study (CMS) dated July 15, 1998. These are site specific, health based clean up standards selected by EPA for the KCP. 4-methyl 2-pentanone, however, did not have clean up standards, established as a part of this CMS. Woodward Clyde Federal Services, who along with EPA derived the original clean up standards established a health based soil clean up standard for 4-methyl 2 pentanone utilizing the same calculations and assumptions used in the Multi-Site CMS. Additional calculations for the same compound utilizing the soil saturation concentration methodology employed by EPA were also made. The lowest of the two calculated values (the “Health Based Clean Up Goal”) was chosen as the site specific clean up standard for concrete included in Table 1. Use of soil clean up standards for concrete is ultra conservative as it assumes ingestion of the concrete. The specific calculations are provided as Attachment II to this certification.

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Table 1 Maximum Concentrations of Compounds Detected in Test Cell 11

Concrete Chip Samples

CONSTITUENT

MAXIMUM CONCENTRATION


CLEAN UP STANDARDS

(µg/kg)

4-METHYL-2-PENTANONE

56,000 585,000

XYLENE 45,000 300,000 TOLUENE 120 635,000 ETHYLBENZENE 6,100 283,000 ACETONE 260 4.1235E+07 BARIUM (TCLP) 234 LEAD (TCLP) 77.4 SELENIUM (TCLP) 222 SILVER (TCLP) 12.2 CHROMIUM (TCLP)

109

• Organic compound levels detected in the concrete chip samples from Test Cell 11 are well below all health based site specific clean up standards. Nevertheless, two additional samples were collected from this Test Cell on April 29, 1998 to determine if the coating was the cause of the compounds detected. The first sample was that of surface coating from the floor of the Test Cell. Results were as follows (µg/kg): 4-methyl -2-pentanone = 930,000 ethylbenzene = 130,000 xylene = 940,000 toluene = 6,500 acetone = ND

Constituent ratios of the coating sample are similar to that of the concrete chip samples with 4-methyl-2–pentanone being the dominant constituent followed by xylene, ethylbenzene and toluene. Overall concentrations of the coating sample are greater than the concrete samples possibly due to absence of matrix dilution from the concrete containing sample.

In addition, one sample from the wall which contained no coating was collected with the following results (µg/kg): xylene = 7.9

The similar compound ratios of coating to concrete chip samples and the overall absence of contamination in the wall samples collected from Test Cell 11 suggests the coating as the source of 4-methyl-2-pentanone, ethylbenzene and toluene contamination and much of the xylene contamination.

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• Chip sample analytical results of TCLP metals detected barium, chromium, lead, selenium and silver up to the concentrations shown in Table 1. The type and concentration of these constituents found in Test Cell 11 concrete were compared to levels found in cement in the document entitled, An Analysis of Selected Trace Metals in Cement and Kiln Dust, by the Portland Cement Association (PCA) provided as Attachment I. The TCLP levels for lead and selenium were 77.4 µg/L and 222 µg/L, respectively and exceeded TCLP levels provided for cement in the PCA document. However, these levels are well below the 5,000 and 1,000µg/L values which would render the material hazardous under RCRA. The PCA document analyzes only the composition of cement a component of concrete, whereas surface analysis for contamination performed as a part of the RCRA closure sampled and analyzed concrete which in addition to cement contains rocks of varying size fractions. Both lead and selenium are common components in the earth’s crust. An exposure assessment was performed as a result of these detections and is provided as Attachment III. This assessment concluded that under current and foreseeable future scenarios no significant exposure is anticipated and no further action is recommended.

• As shown in Table l, no organic compounds were detected at concentrations above site

specific clean up standards. Furthermore TCLP levels for inorganic constituents sampled in Test Cell 11 were well below levels which would render the material hazardous under RCRA. The exposure assessment performed for these trace metals concluded no significant risk exists. For these reasons no further concrete sampling is recommended.

Subsurface Soil Investigation • Two (2) soil borings were drilled in this Test Cell. One boring was drilled through the floor

while the other was drilled through the containment sump. Each sample was analyzed for constituents identified in the Closure Plan.

• Toluene, ethylbenzene, 2-butanone and xylene were detected from the floor boring at the 5

foot depth. 2-butanone and xylene were detected at the one foot depth from the containment sump with xylene detected at 5 feet. Maximum concentrations of compounds detected are listed in Table 2 along with site specific clean up standards found in the Multi-Site CMS. No site specific clean up standard for 2-butanone was established as a part of the Multi-Site CMS. Clean up levels for this compound were calculated in the manner described above for 4-methyl-2-pentanone. Specific calculations are provided in Attachment II. Barium and selenium were also noted in soil samples from TCLP analysis at 1,710 and 150 µg/L. These values are well below the 5,000 and 1,000 µg/L levels for barium and selenium which would render the material hazardous under RCRA. The presence of these constituents is consistent with native uncontaminated soils1.


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Table 2 Maximum Concentrations and Clean Up Standards for Soil Samples in

Test Cell 11

CONSTITUENT

MAXIMUM CONCENTRATION


CLEAN UP STANDARDS

(µg/kg)

2-BUTANONE 41 15,228,000 XYLENE 150 300,000 TOLUENE 7.3 635,000 ETHYLBENZENE 12 283,000 BARIUM (TCLP) 1,710 SELENIUM (TCLP)

150

Determination of Rate and Extent • Contamination by organic compounds detected in Test Cell 11 soil borings are well below

site specific clean up standards. The presence of inorganic parameters from TCLP analysis are well below RCRA levels and are indicative of native soils. For these reasons, no determination of rate and extent is necessary and no further closure activities are recommended.

UP

UP

UP

UP

47 2/ 3

/44 12

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Containment

Sump

XF47 2/3

XG47 2/3

Test Cell 11

1

2

DrawingTitle:

ProjectTitle:

Date:

RCRA Lot Closure


01/22/2013

6

TEST CELL 11

UNITED STATES DEPARTMENT OF ENERGY … Section...1 Jon J. Connor and Hansford T. Shacklette,...

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