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Final

Corrective Action Decision

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jmsasDepartment of Health

and EnvironmentEnvironmental Remediation

Cintas - Mead Street

2212 South Mead Street

Wichita, Kansas

June 2013

KANSAS DEPARTMENT OF HEALTH AND ENVIRONMENT

FINAL CORRECTIVE ACTION DECISION

CINTAS MEAD STREET SITE

Wichita, Kansas

DECLARATION OF REMEDIAL ACTION SELECTION

SITE NAME AND LOCATION

Cintas Mead Street Site

Wichita, Sedgwick County, Kansas

STATEMENT OF BASIS AND PURPOSE

This Final Corrective Action Decision (CAD) document presents the remedy selected toaddress contamination at the Cintas Mead Street Site (Site) in Wichita, Kansas. The Siteis located at 2213 Mead Street, Wichita, bounded by East Kinkaid Street to the north, acity alley between South Mead Street and South Santa Fe to the west, and South MeadStreet along the east, in Sedgwick County, Kansas. The Site is located within the largerGilbert and Mosley Site, an area of regional groundwater contamination.

Since 1995, various investigations have identified several volatile organic compounds(VOCs) in soil and groundwater at concentrations well above the corresponding KDHETier 2 Levels or federal Maximum Contaminant Levels. In general, contaminantconcentrations in groundwater at the Site have decreased over the period of record as aresult of interim source abatement measures aud natural processes. Interim measures forsoil at the Site resulted in removal of the majority of the soil source at the site through useof excavation and soil vapor extraction (SVE).

The Source Control Measures Report (SCM) focused on the evaluation of several remedialaction alternatives to address groundwater and any remnant soil contamination at the Site.The remedial action selected for the Site was based on documents and information

contained in the Administrative Record File for the Site.

DESCRIPTION OF THE SELECTED REMEDY

KDHE has determined that the selected remedy, described in the final CAD, satisfies ormeets the criteria established for selection and will be protective of human health and theenvironment. The selected remedy includes a comprehensive groundwater monitoringprogram utilizing monitored natural attenuation, five-year performance reviews, historicalsoil remediation activities, and Environmental Use Controls (EUCs). The maincomponents of the selected remedy are summarized below:

• Long-term Groundwater Monitoring - Long-term groundwater monitoring will beconducted to determine whether the proposed remedial strategy is effective at reducing

contaminant concentrations to acceptable levels. Additional monitoring wells may beadded if deemed necessary. The groundwater monitoring program will continue untilconditions at the Site meet the requirements of KDHE Bureau of EnvironmentalRemediation's (BER) Reclassification Plan (Policy #BER-RS-024). Once KDHEdetermines the groundwater monitoring program is no longer needed, the monitoringwells will be properly plugged in accordance with Kansas Administrative Regulation(KAR) 28-30.

• Five Year Reviews - Five-year performance reviews will be conducted to evaluate theeffectiveness of the proposed remediation activities and demonstrate that the remedialstrategy continues to be protective of human health and the environment.

• Land Use Controls - Institutional controls, in the form of existing and newEnvironmental Use Controls (EUCs) will restrict future use of the former Cintasproperty and prevent human exposure to contaminated media. This will include aprohibition on the installation of new consumptive use water wells on the Site.

• Soil Contamination - Soil excavation and use of SVE resulted in removal of the

majority of the soil source area at the Site. Potential soil contamination under aconcrete footer that could not be removed will be addressed in the EUCs for the Site.

• Contingency - In the event that Cintas is unable to implement the selected remedy intotal or if the remedy proves ineffective, KDHE may require contingencyimplementation. Contingency actions may include expanded implementation ofcertain components of the preferred alternative or other alternatives as appropriate toensure protection of human health and the environment.

DECLARATION;

The selected remedy will be protective of human health and the environment and attainState, Federal and local requirements that are applicable or relevant and appropriate. Theselected remedy also actively reduces the toxicity, mobility and volume of contaminationidentified at the Site. In selecting and declaring this remedy, KDHE believesimplementation of this remedy will have a beneficial effect by reducing the toxicity,mobility and volume of contaminants.

loizk (aDate

Robert Moser, M.D.Secretary of Kansas Department of Health and Environment

Final Corrective Action Decision "FCa.TlS3.SCintas Mead Street - Wichita, Kansas Dement urifcihhJune 2013

and EnvironmentKmhvnmt rual RtaiiStiiin/i

TABLE OF CONTENTS

SECTION PAGE

1. Purpose ofthe Final Corrective Action Decision -1 -2. Site Background -2-2.1. Site Location - 2 -

2.2. Site History -2-2.3. Water Supply and Well Survey - 3 -3. Source Control Investigation - 3 -3.1. Site Hydrogeology -4-3.2. Summaryofthe Source Control Investigation Results - 4 -3.3. Summary of VaporIntrusion Assessment Results -4 -4. Summary of Interim Measures at the Site - 5 -5. Site Risks - 6 -

6. Remedial Action Objectives - 6 -6.1. Cleanup Levels - 6 -7. Summary of Remedial Alternatives Evaluated - 7 -7.1. Remedial Alternatives - 7-

8. Description of the Preferred Remedy - 8 -9. Community Involvement - 10 -10. Documentation of Minor Changes -10 -

TABLES -11-

Table 1. Site-Related Contaminants of Concern in Groundwater - 12 -

Table 2. Site-Related Contaminants of Concern in Soil -12 -

Table 3. Cleanup Levels for Soil and Groundwater -13 -Table 4. Remedial Alternative Costs for Cintas Site, Wichita, Kansas - 14 -

FIGURES -15-

Figure 1. Cintas Site within the Gilbert & Mosley Area - 16-Figure2. Location of Cintas Site Wichita, Kansas - 17-Figure 3. Potentiometric Surface Map of Shallow Wells Cintas Site - 18 -Figure 4. Sampling Location Map for Cintas Site -19 -Figure 5. Location of Interim Measures Implemented at Cintas Site - 20 -

n

Final Corrective Action Decision

Cintas Mead Street - Wichita, Kansas

June 2013

KansasDepartment oTI Ec:itlli

and Environment£m inamisxl Ef.imibaliui

Acronyms and Abbreviations Used in This Document

ao Administrative Order RUS Rental Uniform Service

AECOM AECOM Environment SCM Source Control Measures

ARARs Applicable or Relevant Report

and Appropriate Site Cintas Mead Street

CAD

Requirements

Corrective Action

Decision

Camp Dresser andMcGee

SVE

TCE

Soil Vapor Extraction

Trichloroethene

CDMMg/kg

Mg/L

micrograms per kilogram

micrograms per Liter

cis 1,2-DCE

coc

cis 1,2-Dichloroethene

Contaminant ot Concern

VOC

VC

Volatile Organic Compound

Vinyl chloride

Cintas Cintas Corporation

ENVIRON Environ International

Corporation

EPA U.S. Environmental

Protection Agency

EUCs Environmental Use

Controls

ISCO In Situ Chemical

Oxidation

KDHE Kansas Department ofHealth and Environment

MCLs Maximum Contaminant

Levels

MUST MUST Rental Uniform

Service

NCP National Oil and

Hazardous Substances

Pollution ContingencyPlan

OMNI Omni Services, Inc.

PCE Tetrachloroethene

RAOs Remedial Action

Objectives

RSK Risk-Based Standards for

Kansas

111



June 2013

1. Purpose of the Final Corrective Action Decision

KsansasDepai'lmenl of Health

and Environmentrj wul Rt-si?tihiitt*t

The primary purposes of the Final Corrective Action Decision (CAD) are to: 1) summarizeinformation from the key site documents including various investigations constituting the SourceControl Measures Report1-2 (SCM) 2) brieflydescribe the alternatives for site remediation

detailed in the SCM; 3) identify and describe theKansas Department of Health andEnvironment's (KDHE) preferred remedy for thesoil and groundwater contamination at the CintasMead Street site (Site); and, 4) documentcomments and KDHE's responses to the publiccomments received regarding the draft CAD.The public was encouraged to review on thedraft CAD during the public comment periodfrom March 26 to April 26, 2013.

KDHE selected a final remedy for the Site afterreviewing and considering all informationsubmitted during the 30-day public commentperiod. Environ International Corporation(ENVIRON) and AECOM (AECOM) preparedthe key documents for the Site. Work performedduring the SCM process followed the termsoutlined in the April 7, 2004 AdministrativeOrder (Case No. 04-E-0066) between KDHE andCintas Corporation (Cintas). The public wasencouraged to review and comment on thetechnical information presented in the SCM report and other documents contained in theAdministrative Record file. The Administrative Record file includes all pertinent documents andSite information that form the basis and rationale for selecting the final remedy. TheAdministrative Record File was, and still is, available for public review during normal businesshours at the location shown in Highlight 1. Also, as shown, a local information repository for theCintas Site is available during normal business hours at the City of Wichita's EnvironmentalHealth Offices.

Highlight 1: Public Information

Administrative Record File

Kansas Department of Health andEnvironment

Bureau of Environmental Remediation

1000 SW Jackson Street; Suite 410

Topeka, Kansas 66612-1367Contact: Margaret TownsendPhone:785-296-1936

E-mail: [email protected]

Local Information Repository

City of Wichita Department of Public Worksand Utilities

Environmental Health Division

1900 E. Ninth Street

Wichita. Kansas 67214

Contact: Shawn Moloney :Phone:316-268-8351

E-mail: [email protected]

1ENVIRON, 2005, Source Control Measures Report and Interim Remedial Action Workplan, Former RentalUniformServices Facility, Wichita, Kansas, approved February 2005.

2AECOM, 2011, Source Control Measures Report, Cintas -September 2011.

1

MeadStreet, Wichita, Kansas, approved

Final Corrective Action Decision'#•;•:•• •-••.••v.T!

Cintas Mead Street - Wichita, Kansas -^^^,0.11^June 2013 ,^:=I,

2. Site Background

2.1. Site Location

The Cintas Mead Street facility is located at 2213 South Mead Street, Wichita, bounded by EastKinkaid Street to the north, a city alley between South Mead St. and South Santa Fe to the west,and South Mead St. ajongthe east, situated in the SW of Section 33, Township 27 South, Range1 East, Sedgwick County; Kansas: The Site is located within the larger Gilbert and Mosley Site,an area of regional groundwater contamination, as shown on Figures 1 and 2 .

2.2. Site History

The original building at the Cintas facility was constructed in 1965 and initially occupied byModel Shop Towel. From 1966 to 2002, the site was used as a uniform rental service facility,which included laundering operations, first by MUST Rental Uniform Services (MUST) through1994, then later by Rental Uniform Services (RUS) until May 2002, when Cintas acquired theproperty as part of an acquisition of Omni Services, Inc. (Omni), a parent company to RUS. Drycleaning was reportedly performed, using tetrachloroethene (PCE) as a cleaning fluid, at the Siteby MUST from the mid- 1960s until the 1970s or early 1980s.

In 1995 CDM, on behalf of the City of Wichita, installed eight direct-push soil borings forgroundwater samples at and in the vicinity of the Site as part of the source area investigation forthe larger Gilbert and Mosley area4. The volatile organic compounds (VOCs) PCE,trichloroethene (TCE), a degradation product of PCE, and cis 1, 2-Dichloroethene (cis 1, 2-DCE), a degradation product of TCE were detected in groundwater at concentrations aboveKDHE's Tier 2 Levels for groundwater as specified in the Kansas Risk-Based Standards forKansas (RSK) Manual5 and the, U. S. Environmental Protection Agency (USEPA) maximumcontaminant levels (MCLs) shown in Table 1.

In March 20021, an environmental assessment of the Site was conducted as part of Cintas'acquisition of Omni. Soil and groundwater sampling wereperformed. PCE was detected.in soilsat a concentration of 7,600 micrograms per kilogram (ug/kg), whichexceeds the KDHE's Tier 2Levels3 for the soil-to-groundwater protection pathway of 121 ug/kg (Table 3). PCE and TCEwere detected in the groundwater at concentrations of 27 micrograms per liter (ug/L) and 6.6Hg/L respectively. Both concentrations exceed KDHE's Tier 2 Level and the MCL forgroundwater of 5 ug/L for both compounds.

AECOM, 2012, June 20,12Semi-Annual Groundwater MonitoringReportCintas: FormerRUSFacility, Wichita,Kansas, Approved by KDHE October 2012.

4CDM, February 1999, Identification and. Evaluation ofPotential Source Areas, Wichita, Kansas, Gilbert andMosley Site, Appendix A, p.18.

• KDHE, 2010, Risk-Based Standardsfor Kansas (RSK) Manual, October, 2010, available at the KDHE website:http://vAvw.kdheks.gov/remedial/downIoad/RSK_Manual_10.pdf.

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Final Corrective Action Decision K._lliS_iSCintas Mead Street - Wichita, Kansas (^Wm^-ii^i,

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During this assessment TCE was detected in water in one of the settling basins at a concentrationof 110 ug/L^, PCE was detected in sediment in one of the settling basins at a concentration of1*500 ug/kg. As a result of these findings a clean-out of the facility's two former settling basinswas conducted in February 20036. The cleanout included the removal and off-site disposal ofboth water and sediment. Additional direct-push sampling of groundwater in 2004 showedexceedance of PCE and/or TCE KDHE Tier 2 Levels in shallow samples downgradient from thePCEdrum storage area at the Site1.

On April 7, 2004 KDHE issued an Administrative Order for Cintas to address contamination atthe Site. Additional sampling at the Site, pursuant to the Administrative Order, confirmed thepresence of soil and groundwater contamination at the Site.

The She is currently vacant, located in an area of diversified land use, including commercial,residential, and light industrial uses; It is located within the Gilbert and Mosley Site, an area ofregional groundwater impacts. VOCs, including PCE, TCE, cis- 1, 2-DCE and vinyl chloride(yG) were identified at elevated concentrations in the soil and groundwater on the property andin the downgradient flow direction to the south-southwest.

2.3. Water Supply and Well Survey

The Site and surrounding vicinity are located within an urban area with an available municipalwater supply. The City of Wichita supplies drinking water to the Site as well as to surroundinghomes and businesses. Drinking water for the City of Wichita is obtained from two upgradientsources: the Cheney Reservoir is located approximately 15 miles west of Wichita, and theWichita well-field which obtains groundwater from the Equus Beds Aquifer is locatedapproximately eightmilesnorthwest of the city.

AECOM2 conducted a water well survey for the area in preparation for their work plan for theimplementation of remedial actions at the Site. No wells were identified as being used asdrinking water sources in the Site vicinity. Wells were identified that are used for groundwatermonitoring, industrial, irrigation, and air conditioning purposes. Wichita Municipal Code Section7.30.105 prohibits the installation of wells for domestic or irrigation uses within areas ofidentified groundwater impacts such as the Gilbert-Mosley groundwater plume.

3. Source Control Investigation

The remedial investigation process was conducted in several phases and includes the collectionof approximately 150 groundwater samples and approximately 70 direct-push soil-samplescollected since 2005. In 2010-2012, AECOM conducted a vapor intrusion assessment whichincluded soil vapor, indoor air, sub-slab, and ambient air testing. The various investigations wereconducted to achieve the following objectives of the source control process:

6ENVIRON, 2004, Work Plan, Former Rental Uniform Services Facility, Wichita, Kansas, approved August 2004.-3-

Final Corrective Action Decision lV3.n S3.SCintas Mead Street - Wichita, Kansas D^im.nionkaui,

• _ —*-* i o and EnvironmentJune 2013 r™;,,.™.^*™*,-,,,,

• characterization and identification all significant source areas, determination ofcontaminants of concern (COCs), mechanisms of release, estimated quantities of release,and determining if releases are ongoing or inactive;

• determining the vertical and horizontal extent of contamination for each impactedenvironmental media to facilitate development of and evaluation of effective remedialalternatives;

• characterization of the environmental setting, including regional and local geology,hydrology, and hydrogeology;

• characterize the chemical and physical properties of each COC, their mobility andpersistence in the environment, and their important fate and transport mechanisms;

• identification of any human and environmental targets that may be affected bycontamination; and,

• developing individual source control plans for those areas identified as "hot spots" orareas of highest contamination.

3.1. Site Hydrogeology

The observed lithology at the Site consists of alluvium from the Quaternary Arkansas River with10 feet of clay overlying 10 to 15 feet of silty fine-grained sand; 15-37 feet of medium to coarsegrained sand which overlies grey-green, soft to hard Permian aged Wellington Shale, which is thebedrock for the area. A single unconfined aquifer is present at the Site, with a water table ofapproximately 16 to 20 feet below ground surface. The groundwater flow is generally to thesouth-southwest (Figure 33).

3.2. Summary of the Source Control Investigation Results

The data collected through the various investigations conducted at the Site showed elevatedconcentrations of VOCs in soil and groundwater both at the former Cintas facility and extendingdowngradient. Table 1 presents a summary of analytical results for the primary COCs ingroundwater and Table 2 presents a summary of analytical results for soil. The locations for soiland groundwater sampling points are shown in Figure 4. Additional information regardingsource control investigation activities is available in the administrative record file.

3.3. Summary of Vapor Intrusion Assessment Results

In February and July 20102 Cintas performed soil-vapor sampling at three depths at ten locationsacross the Site and sub-slab sampling was performed at two residences in July 2010. All of thesevalues are above the adjusted KDHE Tier 2 values for PCE in soil-vapor and sub-slab mediaadjusted7 samples.

7KDHE, 2007, Kansas Vapor Intrusion Guidance, http://www.kdheks.gov/remedial/vapor_intrusion.html.-4-

Final Corrective Action Decision IV^Tl ^sPi <sCintas Mead Street - Wichita, Kansas DSSm.murii„i,hJune 2013

and Environ in cut

As a follow up to the previous work in July8, in December9 2011 and February9 2012 indoor airand sub-slab sampling was performed for a vapor intrusion evaluation of residences adjacent toand slightly downgradient from the Site. Results from these evaluations indicated that cuirentlyno vapor intrusion threat was identified.

4. Summary of Interim Measures at the Site

Several interim measures were undertaken at the Site since contamination was identified from

1995-2002. The locations ofthe interim measures are shown on Figure 5.

• In February 20036 two former on-site settling basins were cleaned out. PCEconcentrations in sediment ranged from non-detect to 1,500 jig/kg. TCE was detected inone settling basin water sample at a concentration 110 ug/L. Sediment and water wereremoved and disposed offsite as non-hazardous special wastes.

• Cintas10 performed a soil excavation of 115 tons ofshallow soil to a depth offive feet forremoval of PCE and TCE in 2005.

• Cintas installed a soil vapor extraction (SVE) system10 at the western edge of the Site toaddress contamination in deeper soils in July 2005. The system operated until March200711 when decreased VOC concentrations in groundwater resulted in thediscontinuation of the system.

• In February - March 201112 Cintas performed a soil excavation to the south, west, andeast of the previous excavation done in 2005. A total of 546 tons of soil was removedfrom the excavation that measured 14 ft x 14 ft by 6.5 ft to 7 ft. Confirmation samplesindicated that contaminants were removed from excavated area (Table 2).Photoionization detector (PID) readings indicated potential VOC concentrations in soilbeneath and around a cement cube in the southwest corner of the excavation that could

not be removed nor could samples be collected beneath this impediment.

The total cost for interim measures at the Site is $188,756.

AECOM, 2011, July2011 Semi-Annual Groundwater, Sub-slab, Soil Vapor, andIndoor AirMonitoring Report,CintasFormerRUSFacility, Wichita, Kansas, approved by KDHE November 2011.

9AECOM, 2012, Semi-Annual Monitoring and Supplemental Indoor Air Monitoring Report, Cintas, Former RUSFacility, Wichita, Kansas, approved by KDHE April 2012.

10 ENVIRON, 2005, Quarterly Progress Report, 2213 South Mead Street, Wichita, Kansas, approved July 2005." ENVIRON, 2007, Semi-Annual Progress Report; January through June 2007,2213 South Mead Street, Wichita,

Kansas.

12 AECOM, 2011, Soil Interim Remedial Measures Report, Former Rental Uniform Services Facility, 2213 SouthMeadStreet, Wichita, KS, KDHE Administrative Order 04-E-0066, approved by KDHE June2011.

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Final Corrective Action Decision 1V3.T1S3.SCintas Mead Street - Wichita, Kansas Dement„fii_i.iiI, ._ _ om O raid Environment

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5. Site Risks

Contaminant concentrations in groundwater (as of July 2012) range from non-detect (ND) to 67.4ug/L for PCE and from ND to 10.2 ug/L for TCE which exceed MCLs (Table 4) and thereforecould pose an unacceptable risk to receptors using groundwater for drinking or other householduses. The City of Wichita Municipal Code of Ordinances, Title 7, Chapter 7.30, Section7.30.105 currently prohibits the installation of new wells and use of pre-existing water wells forpersonal use in contaminated areas (such as the Cintas Site); however, groundwater may be afuture source ofdrinking water.

Various interim measures have removed the bulk of the soil contamination at the Site. Residual

contamination may remain near a cement block in the southwest comer of the 2011 soilexcavation (Figure 5). The entire footprint of the original facility is capped with concrete thuspreventing infiltration of surface runoff to groundwater. The Gilbert & Mosley groundwaterextraction and treatment system provides additional protection via treatment ofany contaminatedgroundwater that migrates from the Site.

Vapor intrusion work at the Site indicated that this pathway is not complete and does not pose athreat to human health or the environment at this time.

6. Remedial Action Objectives

Based on the information collected during the SCM process, the following remedial actionobjectives (RAOs) were developed:

For soil:

• Prevent exposure to and minimize leaching from soils with VOC contamination aboveKDHE Tier 2 Levels;

For groundwater:

• Prevent or minimize further migration of the contaminant plume and restore groundwaterto allow for its most beneficial uses (e.g., drinking water);

• Prevent ingestion of, and dermal contact with, impacted groundwater;

6.7. Cleanup Levels

For groundwater cleanups being conducted at sites with drinking water aquifers, federallypromulgated MCLs are used. Even though groundwater in the vicinity of the Site is not currentlyused for drinking purposes, it is a potential source of drinking water in the future. Therefore,MCLs, where available, and KDHE's Tier 2 Levels for groundwater as specified in the current

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Final Corrective Action Decision IV3.T1S3.SCintas Mead Street - Wichita, Kansas D^Wn.om„iihI om O u,lt'Environment

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version of the RSK manual5 are the final remedial goals for groundwater with consideration ofpotential upgradient contaminant concentrations. For soil, KDHE's Tier 2 Levels for the Soil-to-Groundwater Protection Pathway are the ultimate cleanup levels for the Site. Table 3summarizes soil and groundwater cleanup levels for the Site.

7. Summary of Remedial Alternatives Evaluated

Through the SCM process, individual remedial action alternatives were first evaluated withrespect to their ability to satisfy the following criteria as specified in the National Oil andHazardous Substances Pollution Contingency Plan13 (NCP): protection of human health and theenvironment, compliance with applicable or relevant and appropriate requirements (ARARs);long-term effectiveness and permanence, reduction of toxicity mobility or volume throughtreatment; short-term effectiveness; implementability; and, cost. Costs provided (Table 4) arebased on anticipated future costs and do not explicitly include costs for the interim measuresdescribed in Section 4.0. A detailed description of each remedial alternative is presented in theSCM Report.

7.7. Remedial Alternatives

Remedial Alternative 1 - No Action

The No Action alternative provides a baseline for evaluating all other remedial alternatives.Consistent with EPA guidance, the SCM Report included discussion of interim measures whichaddressed the majority of soil contamination at the Site. However, the No Action alternativedoes not address residual risk present due to contaminant concentrations above KDHE Tier 2Levels for groundwater at the Site. No sampling is included in this alternative to verify anyreductions in conlaininant concentrations over time and no exposure controls are included in thisalternative. Since no action is taken, risks to human health and environment may not beaddressed. The estimated cost of this alternative is $0.

Remedial Alternative 2 - Environmental Use Controls and Monitoring

Alternative 2 uses monitored natural attenuation (MNA) as an approach for achieving the RAOsfor impacted groundwater at the former RUS facility. This alternative also includesEnvironmental Use Controls (EUCs) and groundwater restrictions. The EUCs would apply toSite use and exposure of groundwater and to exposure to subsurface soil in the vicinity of aconcrete footer associated with the foundation of the former building and would be limited to thearea directly beneath the footer and to where the footer meets the adjacent alleyway (SW corner,Figure 5). Potential decreases in contaminant concentrations will be monitored by comparingchemical results obtained from semi-annual sampling. Reductions in contaminant concentrationsare expected to occur as a result of the soil excavation and also as a result of natural attenuation.In order to evaluate the suitability of natural attenuation occurring at the Site, specific parameters

13 National Oil andHazardous Substances Pollution Contingency Plan, 40CFR 300 et seq.-7-

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will be monitored as specified in KDHE Bureau of Remediation (KDHE-BER) Remediationpolicy BER-RS-042 Monitored NaturalAttenuation of Volatile Organic Compounds in Groundwater14 (available online athttp://www.kdheks.gov/ber/policies/BER_RS_042.pdf).

Institution of EUCs for restricted areas for soils and for the Site for groundwater will provideprotection for human and health and the environment. Soil vapor hazards are expected todecrease based on the removal of soil COCs and future degradation of COCs in groundwater.

The estimated cost for Remedial Alternative 2 is $70,000 over a two year time period aspresented in the SCM report2.. KDHE. anticipates that the amount of time necessary to achieveRAOs will exceed the estimated timeframe provided in the SCM2 report. A cost estimate for athirty year timeframe is at least $280,000. If future expenses are higher than those used in theestimate then these costs, may be biased low:

Remedial Alternative 3 - Groundwater Monitoring, In Situ Chemical Oxidation (ISCO),

and Natural Attenuation, and Environmental Use Controls

This alternative includes groundwater monitoring, the use of in situ chemical oxidation (ISCO)with potassium permanganate as the oxidant of choice to address chemical "hot spots" in thegroundwater, natural attenuation, and EUCs. In. order to evaluate the suitability of naturalattenuation occurring at the Site, specific parameters wijl be monitored as specified in KDHE-BER Remediation policy BER-RS-04214.

This remedy would provide direct protection of human health and the environment through theirreversible oxidation of chlorinated COCs contributing to the Site. Post-injection monitoringwould be implemented in conjunction with the remedy to evaluate changes in COCconcentrations. Further discussion of the ISCO option is presented in the SCM report2, section5.3.5.

The estimated cost for Remedial Alternative 3 is $280,000 for a minimum of four years aspresented in the SCM report2 plus the cost of the EUC of $10,000 for a total of $290,000.KDHE anticipates that the amount of time necessary to achieve RAOs will exceed the estimatedtimeframe provided in the SCM2 report. An estimated thirty year timeframe would add anadditional $210,000 for six annual and then four five year performance monitoring events ifneeded for a total cost of $500,000. If future expenses are higher than those used in the estimatethen these costs may be biased low.

8. Description of the Preferred Remedy

On the basis of information available in the Administrative Record and summarized above,KDHE has determined that the preferred remedy for the Site, outlined below, satisfies or meets

14 KDHE-BER, 201.1, KDHE-BER Remediation policy BER-RSr042 Monitored Natural Attenuation of VolatileOrganic Compounds in Groundwater (http://www.kdheks.gpv/ber/policies/BER_RS_042.pdl).

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the criteria established by both State and Federal programs and will be protective of humanhealth and the environment. KDHE recommends implementation of the proposed remedial planwith consideration of any comments received from the public during the 30-day comment period.

KDHE has identified Remedial Alternative 2 as the preferred remedy for addressing the soil andgroundwater contamination at and downgradient of the Site.

This remedial alternative incorporates land use controls, in the form of EUCs, to restrict futureuse of theproperty. In addition, City of Wichita Municipal Code of Ordinances, Title 7, Chapter7.30,. Section 7.30.105 currently prohibits the installation of hew and use of pre-existing waterwells in contaminated areas.

The existing groundwater monitoring network will continue to be utilized under the preferredremedy for groundwater; however modifications to the monitoring network will be implementedas appropriate. The soil excavation interim measure removed the contaminated soil at the Site:However, it should be noted that possible residual soil contamination in the vicinity of thecement block near the building footing at the southwest corner of the 2011 excavation (Figure 5)may continue to act as a source of groundwater contamination. The use of.monitored naturalattenuation assumes that natural attenuation processes will assist in the remediation of thecontaminants in groundwater. The Site is within the groundwater extraction and treatment areaof the Gilbert & Mosley system and any residual COCs not remediated by the interim measuresused at the Site should be captured by this system. Five year reviews will be conducted as long ascontamination remains at the Site at concentrations above levels which would permit unrestricteduse. These reviews will provide an opportunity to review the overall protectiveness

No additional active remedial measures are proposed for soil at this time. The soil excavationinterim measure resulted in removal of the, majority of the COCs for the Site. SVE effectivelyremediated deeper soil contamination. Any residual contamination will be addressed via EUCsormay beaddressed once structural impediments areremoved.

The cost; of all future remedial actions incorporated in the preferred remedy at the site for anestimated 3.0-year cleanup is $2,80,000. When combined with costs for interim measureimplementation ($188,756) the total cost of remedial actions for the Site is anticipated to beapproximately $468,756.

In the. event that Cintas is unable to implement the preferred remedy as described herein in totalor the remedy proves ineffective, KDHEmay require contingency implementation. Contingencyimplementation would be invoked if MNA was found to not occur in the groundwaterat the Site.Contingency actions will include implementation of ISCO consistent with Remedial Alternative3. Additional costs associated with contingency implementation of the ISCO injections are in therange of $160,000 above the costs of the long-term monitoring.

Final Corrective Action Decision lv£lTl<$Pi<sCintas Mead Street - Wichita, Kansas D^,,1,n.oni,:,iihi. ._ _ OHIO and Environment

JUriG /\j I \5 AiitfiwMiwufftar-.fiirtw

9. Community Involvement

A Public Information Plan for the Site was developed by KDHE. Public input and comment wasencouraged by KDHE throughout the process. Public notice of the availability of the draft CADwas published in the The Wichita Eagle on April 2, 2013 as well as notice of the public commentperiod offered from March 26 to April 26, 2013. As per the Public Relations Strategy, the noticeincluded information for the public availability session held on April 10, 2013 where the publicwas given additional opportunity to ask questions and provide comments on the draft CAD.KDHE established a webpage dedicated to the Cintas Site, which was made available online, andcontinues to be available online, at http://www.kdlieks.gov/remedial/site_restoration/cintas.html.Notice of the public availability session was posted on KDHE's webpage.

10. Documentation of Minor Changes

Minor changes were made to the Draft Corrective Action Decision based on further internalreview. No written comments were received from the public during the public comment period.

10


Cintas Mead Street - Wichita, KansasJune 2013

TABLES

11

KansasDepartment ut'llcuhh

and Environment



KansasDepartmuni of IIciillh

and Environincutfit .rhwc iffii/ «, iKn/farfvu

Table 1. Site-Related Contaminants of Concern in Groundwater

Compound

Historical

Maximum

Concentration

Groundwater

Current Maximum

Settling Basin Concentration MCL or KDHEConcentrations Groundwater Tier 2 Levei

2002 June Semi-annual (Residential)ug/L 2012 ug/L

Mg/L

PCE 180 7.2 87.4 5

TCE 27 110 8.6 5

cis 1,2-DCE66 5.9 3.6 70

Vinyl chloride <2 ND ND 2

Concentrations in micrograms per liter (ug/L).ND means non-detect values for COCs.

*KDHE Tier 2 Levels default to MCLs where available. Tier 2 Level for groundwater provided fromKDHE's Risk Based Standards for Kansas (RSK) Manual, October, 2010.

Table 2. Site-Related Contaminants of Concern in Soil

HistoricalCurrent Maximum!

Concentration ' Confirmation

Compound „ Maximum Non_ Excavated . Samples fromConcentration , Excavation

KDHE Tier 2 Level KDHE

(Soil to Tier 2 LevelGroundwater (Soil

Pathway)* Pathway)*Mg/kg Mg/kg

PCE 22,900 121J/39J Dup < 0.005 121 7,540

TCE 12,900 6.6J < 0.005 84.2 41,000

Chlorobenzene 10,800 ND ND 5,100 380,000

cis 1,2-DCE 36,400 6.5J < 0.005 855 115,000

Concentrations in micrograms per kilogram (Mg/kg).J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting

limit.

ND - Not detected.

Dup - Duplicate sample collected.*KDHE Tier 2 Levels default to MCLs where available. Tier 2 Level for groundwater provided from

KDHE's Risk Based Standards for Kansas (RSK) Manual, October, 2010.

-12-



KansasDepartment urikMllh

mid Environment

Table 3. Cleanup Levels for Soil and Groundwater

Compound

MCL or KDHE

Tier 2 Level* inGroundwater

Mg/L

KDHE Tier2 Level* for,Soil-to-Groundwater

Mg/kg

PCE 5 121

TCE 5 84.2

cis 1,2- Dichloroethene70 855

Vinyl Chloride 2 20.5

*KDHE Tier 2 Levels default to MCLs where available. Tier 2 Level for groundwater provided fromKDHE's Risk Based Standards for Kansas (RSK) Manual, October, 2010.Groundwater concentrations in micrograms per liter (Mg/L).Soil concentrations in micrograms per kilogram (Mg/kg).

13-



June 2013

KansasDepartment of lletillh

and EnvironmentrnWi«i"Fr.-,if,Jirt,,n.-iJjfl:i:w

Table 4. Remedial Alternative Costs for Cintas Site, Wichita, Kansas

Remedial Alternative Costs

Alternative 1 - No Action

Component # Events Cost Per Event Overall Cost

No monitoring or other actions taken 0 0 $0

Alternative 2 - Monitoring with EUCs

EUCs 1 $ 10,000.00 $ 10,000.00

Semiannual Monitoring (Years 1-4) 8 $ 15,000.00 $ 120,000.00

Annual Monitoring (Years 5-10) 6 $ 15,000.00 $ 90,000.00

Monitoring Every 5 Years (Years 11-30) 4 $ 15,000.00 $ 60,000.00

Total $ 280,000.00

Alternative 3 - ISCO and GW Monitoring

EUCs 1 $ 10,000.00 $ 10,000.00

Initial implementation with Bench Study 1 $ 110,000.00 $ 110,000.00

Performance Monitoring 4 $ 15,000.00 $ 60,000.00

Follow-up Injection 1 $ 50,000.00 $ 50,000.00

Performance Monitoring 4 $ 15,000.00 $ 60,000.00

Annual Monitoring (Years 5-10)* 6 $ 15,000.00 $ 150,000.00

Monitoring Every 5 Years (Years 11-30)* 4 $ 15,000.00 $ 60,000.00

Total $ 500,000.00

* Added by KDHE to account for potential need for Long Term Monitoring.

14



June 2013

FIGURES

15

Department ur"Ileallhand Environment

t«i/nW'i.-.i/ K.^J-iilf.u,



June 2013

KansasDepartment of Health

and Environmentfli\!rtitfn,-utti/ Kfir~;i'nilnal

Figure 1. Cintas Site within the Gilbert & Mosley Area

Mmcn)/-- •,-.*;-u||.v:.

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AKOM

FromAECOM, 20122

Cintas Former RUS FacilityWichita. Kansas

PrcleciNo. 60143934

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16-

1250 0 2500

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Site Location Map

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Figure 2. Location of Cintas Site Wichita, Kansas

MICHAC15 COMPLETE LAWN CARE

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KansasDepartment of! Icallh

nnd Environment



MW-5B ff*

MM '1266.95

From AECOM 20123

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Figure 3. Potentiometric Surface Map of Shallow Wells Cintas Site

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Legend-V Monitoring Well Location

Monitoring Well Location(Abandoned)

Approximate PropertyBoundary

s\J\ Water Table ElevationCountour (interval = .I ft msl)

Groundwater Flow Direction

Wastewater Settling Basin

Notes:

(1) Elevation ofCfttas wells based on processbn3lsurveyperforated on June27.2012. Elevation ofGilbert Mostey•el frcm iSi (September2011J.(2) Water levels record*; June 2f. 2012(3) ft msi = Feet above Wean Sea Lenel

30 60 .90

AZCOMPotentiometric Surface !MapShallow Wells

CLrfc FormerRUS FacilityWkbita. KS

Date Created: 81312

120

3 Fee:

H -=3S>~ I

Figure 5

KansasDepartment of"IIcyllh

and LnviroiuneiUt.nv>r'H:*U':! i) &•;•:. .Ir.nu-;



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Modified from AECOM 201012

i

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Figure 4. Sampling Location Map for Cintas Site

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ATCOMSite Layout and Sample Imitation Map

Cintas Former KUS facilityWichita. KS

IWi'idIk-i-2012 Figure 1

KansasDepartment of Ileahh

and l-in ironment



Modified from AECOM 2011n

Figure 5. Location of Interim Measures Implementedat Cintas Site

-20-

Legend

Q ConfiinaliDnSample Location

if 2005 SVEWeI Lo^:ion (Approx Tiats)2006 SVE v'.-ip.o- Men Tnrinrj Pointi ocaion

* (Af&CBdmate)—- Appntamota ProperlyBoundar)

2000 SoilE>:c3vs-.icn (Appro mats)

- ' si Scii Bctawflon - 2C11

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Final Soil Excavation - 2C11

_*_ Former fe-L -g Sa=ins (Ar-crounata)

10 20 40 60 80

I Feet

ATCOA1Locations of Interim Measures

Cintas Former RUS FacilityWichita, K.S

December 2012

N

Figure 2

K ansasIX'partmenl of I leahh

and Environment

CONCURRENCE SHEET

BUREAU OF ENVIRONMENTAL REMEDIATION

DATE: (^^\ -M, la\3

DOCUMENT TYPE: Final Corrective Action

Decision

RECEIVED

JUN 2A2013

OFFICEOF THE SECRETARY

This concurrence form is for your review and comments on the attached document;Please be advised that this is the ORIGINAL INSTRUMENT.

PROJECT NUMBER:C2-087-71869

IN THE MATTER OF: Cintas-Mead Street, Wichita, KS CASE NUMBER: 04-E-0066

jbflAMuwT)

PLEASE RETURN ORIGINAL TO PROJECT MANAGER AFTER SIGNED BY SECRETARY

Received

JUN 20 2013

DIRECTOR OF ENVIRONMENTDEPT. OF HEALTH &ENVIRONMENT

Return to Margaret Townsend , BER, Suite 410

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