S t a t e o f K a n s a s

Bill Graves fcv^sSg Governor A/0!/

S00076041SUPERFUND RECORDS Department of Health and Environment

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James J. O'Connell, Secretary^-,,.- • ^--~ .«i u-. • ,. c £L TNovember?, 1996 j -•'/'' il'^.

!*::~'~^M—.Mr. Bruce A. Morrison j Q- _Ck^——Environmental Engineer I ^_____r__iJ^Jj.— !U.S. Environmental Protection Agency %_„.., .IL .̂——.Region VII726 Minnesota AvenueKansas City, KS 66101

Subject: Revised Draft Site Characterization Report including the Baseline HunHealth Risk Assessment, Former Chemical Commodities, Inc. Site, OlatKansas

Dear Mr. Morrison:

The Kansas Department of Health and Environment (KDHE), Bureau of EnvironmeiRemediation (BER) has completed its review of the revised draft document captioned aboComments are as follows:

Site Characterization Report. Section I. - Section III.

1. Figure 1.0-1, Site Location Map: The title block of this figure was not corrected,correct address for the site is 320 South Blake Street.

2. Pages iii through v, Contents: The organizational hierarchy of the table of conteii.e., numbering system, does not agree with the organizational hierarchy used in the main beof the text. KDHE/BER finds the hierarchical numbering system used in the text is difficulfollow. KDHE/BER recommends changing the text back to the original numbering systtAlso, there are references in the text to other sections in the text which use the old numbersystem. These references are on pages 17, 18, 19, and 20.

Baseline Human Health Risk Assessment. Section IV.

1. Pages 43 through 50, Sections IV.C.3 through IV.D.2: KDHE/BER strongly disagrwith and will not accept the approach used by Rockwell International Corp. for selecting the cset which will be used to evaluate risk for the future on-property residents. The text states (p33)".. .the evaluation of the on-property future resident utilizes the data set from the on-proptarea where the detected chemical concentrations are the highest (Figure 4.1-2)". Fromstatement the reader would assume the data set would be derived from within the highligr

Division of Environment. Bureau of Environmental Remediation Telephor-Forbes Field. Building 740, Topeka, KS 66620-0001

Printed on Recycled Paper

remain vacant and will be subject only to trespassers. The recreational user scenario, which isequivalent to the trespasser scenario, is the least conservative of the scenarios assessed in theBHRA. The property is currently zoned as light industrial. Residential property borders thesite on the west and north. The current land owner, no doubt, would like to return the propertyto its most economic beneficial use. The City of Olathe, one would suppose, would like tomaintain the property at the highest assessment on the tax rolls. It is much easier to rezonelight-industrial property to residential property than it is to rezone residential property to light-industrial property. Therefore, KDHE/BER recommends that Rockwell use a future on-propertyresidential scenario to establish a removal action goal.

5. Page 13, Section 3.2, Other Removal Action Objectives Considered: RockwellInternational has failed to consider fully the further migration and impact of shallow, VOC-contaminated groundwater. The Site Characterization Report has established that shallowgroundwater does flow south from the Chemical Commodities, Inc. (CCI) site. Thus, VOC-contaminated groundwater could potentially migrate from CCI to Mill Creek although this hasnot been documented. Specific discharge points of contaminated groundwater stemming fromthe CCI site to Mill Creek have not been identified. This pathway of contaminant transport toMill Creek is considered a nonpoint source input, where any shallow groundwater may impactthe creek through subsurface flow. This pathway, though not specifically delineated, remainsa current and future consideration.

Four municipal lakes are located within 2,000 feet south of the CCI site. They are:

North Waterworks LakeSouth Waterworks LakeSouth Frisco LakeNorth Frisco Lake

The City of Olathe Water Treatment Plant No. 1 lies immediately southwest of NorthWaterworks Lake. The water treatment plant draws water from South Waterworks Lake, filters,chlorinates, and fluorinates the water and supplies local residences and businesses with drinkingwater. Sludge from backwashing of the filters is dumped into North Waterworks Lake.North Frisco Lake, a municipal recreational lake, is about 500 feet south of the site, and has thehighest probability of being contaminated by CCI VOC-contaminated groundwater. The SouthFrisco Lake, another municipal recreational lake, lies immediately south of North Frisco Lake.

Mill Creek, a tributary to the Kansas River, flows north-northwest about 1,000 feet from thesouthwest boundary of the site. Much of Mill Creek's flow originates from South Frisco Lake,approximately 2,000 feet south of the site. Mill Creek is classified by the State of Kansas(1994) as a Stream Constituting Outstanding Natural Resource Waters. Designated beneficialuses for Mill Creek include the following:

• Domestic Water Supply• Contact Recreation• Aquatic Life Support• Food Procurement

• Groundwater Recharge• Industrial Water Supply• Irrigation• Livestock Watering

Contaminants were reported in the sediments of Mill Creek by previous investigators (PEDCo,1982). However, it remains unclear whether or not contamination attributable to the CCI sitecurrently exists in Mill Creek sediments. Contaminated sediment may be present, may have beeneroded away, or simply may be covered by more recent deposition. Additional sampling wouldhelp to characterize this potentially contaminated medium and determine the potential impact ona natural resource of the State.

Based on the potential detrimental impact posed by the contamination at CCI on the lakes andMill Creek, KDHE/BER recommends that the five (5) Shallow Groundwater Removal ActionAlternatives, which were identified in the Technical Memorandum on Identification of RemovalAction Alternatives (June 19, 1996) for further evaluation in the EE/CA, should be pursued.

6. Page 16-17, Section 3.3.2.2, Potential Federal Chemical-Specific Requirements andTBCs, 3rd paragraph on page 16 and 1st paragraph on page 17: Although it is unlikely thatDNAPLs and dissolved VOC concentrations in groundwater can be reduced below the MCLsusing current technology, there are current technical approaches for containing and treating thecontaminated groundwater on site and, thus, preventing the migration of contaminatedgroundwater to offsite areas. These approaches are summarized in the five (5) ShallowGroundwater Removal Action Alternatives mentioned in Comment 5.

7. Page 17, Section 3.3.2.3, Potential State Chemical-Specific Requirements and TBCs,last sentence of 1st paragraph and last sentence of 3rd paragraph: The statement, "...nosurface water is impacted", has never been established by Rockwell. Previous investigations byPEDCo (1982) suggest that sediments and, thus, surface water along Mill Creek has beenimpacted.

8. Page 21, Section 4.1, Identification of Removal Action Alternatives, 1st bullet, Clay(organic) cap and Figure 4-2: The description of the clay cap and Figure 4-2 do not agree.The description fails to mention the geotextile fabric and that the vegetative cover may be up to2-feet thick.

9. Page 22, Section 4.1, Identification of Removal Action Alternatives, 2nd paragraph:It is KDHE/BER's understanding that the impermeable liner covering the compilation pile,which is located on the southwest corner of the warehouse building, was breached duringinstallation of boreholes through the pile. Were the liner and drainage layer repaired? It isKDHE/BER's understanding that the 1989 removal action, in which between 1,100 and 1,300cubic yards of soil containing VOCs and leachable chromium were relocated and consolidatedinto the compilation pile, was a temporary measure only. KDHE/BER recommends that thecompilation pile be removed and disposed of at the same time the warehouse is demolished andthe concrete floor removed.

10. Page 27, Section 4.1.2, Analysis of Removal Action Alternative 2: Construction andMaintenance of an Asphalt Concrete Cap, Implementability, 3rd and 4th bullets, State andCommunity Acceptance: The State of Kansas, and probably, the adjacent residents as well,will not accept a fenced, asphalt concrete cap adjacent to a residential area. The State ofKansas, and perhaps the community, would accept an aesthetically pleasing, grassed area nextto the residential area.

11. Page 29, Section 4.1.3, Analysis of Removal Action Alternative 3: Construction andMaintenance of a Multimedia Cap, Implementability, 2nd and 3rd bullets, State andCommunity Acceptance: The State of Kansas, and probably the community, would accept avegetated multimedia cap, rather than an asphalt concrete cap. Aesthetically, the vegetatedmultimedia cap would blend more appropriately with the surrounding neighborhood. Also, themultimedia cap is almost as protective as the asphalt concrete cap.

12. Page 31, Section 5.1.2, Comparative Analysis of Implementability, 1st paragraph:The comparison should be made between the three types of caps rather than with the asphaltconcrete cap and the current physical condition and appearance of the site.

13. Page 32, Section 5.2, Recommended Removal Action, 2nd paragraph: KDHE/BERdisagrees with the recommendation of an asphalt concrete cap over a multimedia cap.KDHE/BER believes the multimedia cap is superior to the asphalt concrete cap.

14. Figure 1-1: The title block of this figure is incorrect. The correct address for the siteis 320 South Blake Street, not "Baker" Street.

15. Not Addressed in EE/CA: KDHE/BER recommends that Rockwell address the remedialtechnologies associated with in situ and ex situ treatment of contaminated soils at the site thatwere identified in the Technical Memorandum on Identification of Removal Alternative (June19, 1996).

Please feel free to contact me at 913-291-3249 if you have questions or comments.

Sincerely,

Thomas H. Waller, Ph.D.Environmental Geologist/Project ManagerSuperfund Unit/ Assessment and Restoration SectionBureau of Environmental Remediation

c: Randy Carlson -> CCI File (2.1)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION VII

726 MINNESOTA AVENUEKANSAS CITY, KANSAS 66101

NOY 2 i 1996

Michael J. Sullivan, Ph.D.Rockwell International CorporationPO Box 7922Canoga Park, CA 91309-7922

Dear Dr. Sullivan:

RE: Chemical Commodities, Inc., Superfund Site, Olathe, Kansas

The United States Environmental Protection Agency (EPA) has reviewed the EngineeringEvaluation/Cost Analysis (EE/CA) dated October 29, 1996, submitted by Rockwell InternationalCorporation and hereby disapproves of this EE/CA submittal. The EPA is directing RockwellInternational Corporation to re-submit the EE/CA in accordance with Section IX (c) of theUnilateral Order (Docket No. VII-95-F-0030). The EPA also disapproves of the revised SiteCharacterization Report which includes the Baseline Human Health Risk Assessment.Following are EPA's and the Kansas Department of Health and Environment's commentsthat should be addressed in the re-submittal of both of these documents.

Baseline Human Health Risk Assessment

The future on-site resident and near-site resident exposure scenarios of the BaselineHuman Health Risk Assessment do not consider the migration of contaminated shallow groundwater and vapors from contaminated ground water and soil into basements. The potential for thisscenario to occur would pose potential inhalation and direct contact exposures to VOCcontaminants. Basements typically are eight to ten feet below the ground surface. The depth tosignificantly contaminated soils (with VOCs) is as little as 3.5 feet at some locations at the site.Vapors from this contaminated soil and percolating rain water could enter basements andsubstructures of future buildings placed on site. The Baseline Human Health Risk Assessmentshould evaluate the health risks posed by this scenario.

EE/CA. Section 3.1.

1. Page 11: The determination to address only the current land use i.e.trespasser/recreational and subsequently only the exposure scenario consistent with this land useis the fundamental deficiency of this EE/CA. By not addressing future land use, the removal

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alternatives described in the EE/CA have not adequately addressed the subsurface contamination.High levels of VOCs, including dense non-aqueous phase liquids at the site will most likely

continue to migrate laterally off site posing a threat to enter substructures/basements near thesite.

2. Section 5.2, Page 32: The capping of contaminated soils on site during the 1991 time-critical removal action was designed and implemented as a temporary, partial containmentmeasure. EPA intended for remaining site contamination, including the stockpiled soils, to beaddressed with future actions. This EE/CA and subsequent selected response action is anopportunity to implement a long lasting solution to the remaining site contamination.Rock well's proposed remedy selected in the draft EE/CA does not appear to be a permanentsolution to site contamination. Not only does the proposed remedy fail to treat or remove anysite contamination, but will probably not adequately contain site contaminants, specificallyDNPLs and VOCs.

VOCs have migrated off site and will continue to migrate off site if the sources (on-sitecontaminated soil and shallow ground water) are not addressed with adequate containment,treatment, or removal. Rockwell's proposed remedy does not ensure complete containment ofcontaminants, nor does it propose monitoring for potential future migration of contaminants.Data presented in Rockwell's recent Site Characterization Report indicated that significant VOCcontamination has already migrated beyond the boundaries of the proposed cap removal remedy.Because the proposed cap remedy does not provide assurance that the lateral movement ofground water at the site has been prevented, the horizontal migration of DNPL/VOCs maycontinue after the implementation of the cap remedy. Thus, subsurface conditions at the sitewould continue to pose a threat to nearby residents by leaching into basements and crawl spacesas well as reaching Mill Creek.

No measures have been proposed that would prevent downward migration of DNPLs to adeeper aquifer. Monitoring data for EPA well #3, which is screened in the bedrock, indicatesthat VOC contamination is increasing over time at that location, and therefore, indicates thelikelihood of downward migration of VOC contaminants from the site.

In conclusion, the EE/CA should be redrafted to include an analysis of removalalternatives that provide for the reduction of toxicity and volume of contaminated subsurfacesoils and ground water. EPA recommends that for the revised EE/CA, Rockwell evaluate theremoval alternatives that were presented in their Draft Technical Memorandum on Identificationof Removal Action Alternatives dated June 19, 1996. That memorandum presented removalalternatives that will permanently reduce the toxicity, volume, and mobility of contaminationfound at the CCI Site. The revised EE/CA should provide a selected removal alternative that willreduce the toxicity and volume of VOC contamination at the site as well as reduce the mobilityof site contaminants. A long-term site monitoring program should be included as part of allremoval alternatives presented in the EE/CA.

Please call me at (913) 551-7755 if you have any questions concerning these issues.

Sincerely

BfuceProjectSuperfuni

cc: Barbara Peterson, CNSLTom Waller, KDHE