burns ^ mcdonndl may 9, 2000

Burns ̂McDonndl

May 9, 2000

Mr. Paul RoemermanSuperfund DivisionUSEPA, Region VII901 North 5S StreetKansas City, KS 66101

PCBINC Engineering Evaluation and Cost AnalysisProject No. 96-293-4-009 - PCBINC________

Dear Mr. Roemerman:

Enclosed are seven copies each of the revised EE/CA reports for the 2100 WyandotteStreet, Kansas City, Missouri and 45 South Ewing Street, Kansas City, Kansas,facilities that are collectively referred to as the PCB Treatment, Inc. Site. We havealso mailed one copy of each report to the respective state agencies. These reportshave been revised based on your comment letter dated March 27, 2000 and oursubsequent conversations with you, Mr. Dan Gravatt of KDHE and Ms. CandiceMcGhee of MDNR. We believe these revisions respond to and resolve thecomments in your March 27, 2000 letter. Please note the Steering Committee hasnot responded to Comment #2 regarding moving and moving-related expenses fortenants of the Wyandotte building. This item is subject to dispute under a Notice ofDispute filed by the Steering Committee with EPA on May 5, 2000, pursuant toArticle XIV of the Administrative Order on Consent for this matter.

The following is a brief summary of the changes that have been made to the reports:

Comment 1: Include the Risk Assessment as an Appendix.

Action: The Risk Assessment that was previously included as an Appendixin the RSE has been included as Appendix B to each EE/CA.

Comment 2: Include costs and provisions for providing alternate space fortenants at the Wyandotte facility, including Rosse Lithography. Apreliminary estimate of relocation costs prepared by Rosse Lithographing isattached. The cost estimate in the EE/CA should include moving costs, aswell as some estimate of moving-related costs such as upgrading electricalsystems, reinforcing structure to support their presses, and necessary repairsor improvements to a new building to accommodate the business. Obviously,some assumptions will be necessary to prepare this cost estimate as more

9400 Word ParkwayKommdtyMuoun 64114 3319lei 8163339400fat: 816 3333690www txjrmmd com

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Mr. Paul RoemermanMay 9, 2000

definitive requirements will not be known until potential new locations areidentified and evaluated.

Action: This item is subject to dispute under a Notice of Dispute filed by theSteering Committee with EPA on May 5, 2000, pursuant to Article XIV ofthe Administrative Order on Consent for this matter.

Comment 3: Executive Summary - Include discussion of why PCBs aredangerous to human health or the environment.

Action: A paragraph (paragraph 2) has been added to the executive summaryof each EE/CA discussing potential health and environmental effects ofPCBs.

Comment 4: Provide supporting information on the sources of the estimatesand any assumptions made in calculating them for the cost estimates includedin the report for the viable removal technologies for building and soil(Appendix A).

Action: Additional tables have been added to Appendix A for both EE/CAs.

Comment 5: Delete reference to phthalates not being indicator of PCBs.This is misleading in that if this is not a laboratory cross-contamination, thenit does represent another problem even though it may not have been causedby the presence of PCBs at these facilities.

Action: The last sentence of section 2.4.3 has been removed from bothreports.

Comment 6: Section 1.3, Site History - Include discussion of brewery tocomplete the site's history at the Wyandotte facility.

Action: The following text has been added to the beginning of section 1.3of the EE/CA for the Wyandotte facility: "According to Sanborn maps, thelot was vacant in 1895. By 1909 (the next available Sanborn map), abuilding listed as the P. Schoenhoffer Brewing Company had been built onthe Site."

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Mr. Paul RoemermanMay 9, 2000PageS

Also, the word "current" has been added before the word "building" in whatis currently the first sentence of the section.

Comment 7: Section 2.0 Site Characterization - Expand this section to meetthe requirements of p. 25, O-6, of the Guidance on Conducting Non-TimeCritical Removal Actions Under the Comprehensive EnvironmentalResponse, Compensation, and Liability Act of 1980 (CERCLA). Some ofthis may be referenced to the Site Characterization Reports, but someinformation such as latitude and longitude is lacking and should be included.Also, include a copy of the site maps. Also, in this section includediscussions of past clean-up efforts.

Action: After a review of section 2.4 of the above referenced guidance, itappears that most of the information is included in the SCRs. We have addedan additional reference to the SCRs. The following information was added toeach EE/CA since it was not in either the SCR or EE/CA report: latitude andlongitude of the Site. We also added the statement "Because the site islocated in a large, urbanized metropolitan area and the Site has beendeveloped for commercial/industrial use for more than 75 years, it is notbelieved that sensitive ecosystems are present at the Site." to each EE/CA.

The request for additional maps was discussed with Paul Roemerman ofUSEPA. A topographical site location map and a site survey are alreadyincluded as Figures 1 and 2 in the report and it was agreed that these mapsare sufficient.

A summary of past clean up efforts was taken from each SCR and included inthis section of the appropriate EE/CA.

Comment 8: Section 2.3...Hydrogeology (Kansas Facility) - Explain oreliminate the inconsistency in the calculation of the saturated alluviumthickness under the site between this section and the second paragraph ofSection 2.2.1 of page 2-1. From the available data, it appears the expectedsaturated alluvium thickness would be around 40 feet.

Action: The wording in section 2.3, paragraph 2 has been changed to thefollowing: "The depth to water reported in 1944 for the Kansas GeologicalSurvey's Test Hole 87, which is located Vi mile west of the site, was 21.8 feetbgs (Fishel, 1948). During SCR activities, groundwater was encountered at16 and 20 feet bgs. Based on this data and the approximate thickness of the

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alluvium near the Site, the saturated thickness of the alluvium in the vicinityof the Site is expected to be approximately 40 to 45 feet."

(The underlined portion has been added or changed.)

Comment 9: Section 2.4, Nature and Extent of Chemicals - Spell outSVOCs as this is the first time it is used.

Action: SVOC has been spelled out in both reports.

Comment 10: Section 2.4.4, Concrete - Third paragraph states that all thewall samples were in excess of the clean up level and would be incorporatedinto the figures. However, on the figures, many of the floors have nohatching on exterior walls. Correct this discrepancy.

Action: The titles of the figures have been changed in both reports to clarifythat they are for floor surface contamination (Extent of Floor SurfaceContamination). The text correctly states that all wall samples were in excessof the clean up level. Where a wall sample exceeded the clean up level, thefloor abutting that wall sample has been assumed to be contaminated unlessthat floor grid was sampled. If the grid is assumed to be contaminated basedon the adjacent wall sample, it is hatched accordingly on the figure. Nosamples were taken from the walls of floors 2, 4 and 5 in the Wyandottebuilding. This has been indicated in section 2.4.4 of the Wyandotte report.

The word "separate" was deleted in section 2.4.4, paragraph 3, sentence 6 ineach report.

Comment 11: Section 2.4.6 Tank and Miscellaneous Pipes and Drains -Since the tank's sample results were in excess of the clean up level, the tankshould be hatched in Figure 2-1.

Action: As discussed in the response to comment 10, the figures representfloor surface contamination. It was not possible to sample the floor under thetank, so this area on the figure was not shaded.

Comment 12: Section 2.5.2, Current Structural Condition and Future Use -This section discusses concrete compressive strength below 2,000 psi, but itis unclear if strengths were found to be below that level. Add discussion of

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what tests were found below this level and where in the building they arelocated.

Action: Additional information from the SCR was added to the WyandotteEE/CA to address this issue.

The following text was added to the second paragraph of section 2.5.2 afterthe first sentence: "The concrete compressive strength of two columns wastested. The column in the northeast corner of grid D4 on the first floor andthe column in the northeast corner of grid E4 on the third floor were selectedfor testing. The corrected compressive strength results were 1,646 and 1,498psi, respectively. ASTM standards C39 and C42 were followed and the testresults are included in Appendix F of the SCR."

Comment 13: Section 3.0, Removal Action Objectives - Includediscussion/explanation of the statutory limits on removal actions to help thepublic readers understand the process.

Action: This comment was discussed by Common Counsel for the SteeringCommittee and Ms. Jenna Wischmeyer of Region VII Office of RegionalCounsel. Based on those discussions, Region VII withdrew the comment.

Comment 14: Section 3.1.2, ARARs, first line - "has considered applicableor relevant and appropriate requirements". "(ARARs)" should be added afterthis and then removed from the third line in this section following"requirements".

Action: This has been changed in both reports.

Comment 15: Section 3.2.3, Removal Action Schedule - Expand discussionof doing the work in parallel versus doing it in series, including how thiseffects the schedule with time spans, etc.

Action: The following paragraphs have been added, in both reports, after theschedule outlined in section 3.2.3 discussing the different options.

"Mobilization and completion of Site work may be conducted by a singlecrew or by two full crews using one or two contractors. If the work is doneby two full crews using only one contractor, then the pool of potential biddersmay be limited by the number of large demolition contractors available.

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However, the work at both sites would be completed in a shorter time sincework would be carried out simultaneously. We have estimated that thiswould take approximately 10 months. If two crews are used, each with itsown contractor, the work at both sites could also be carried outsimultaneously and would be completed in approximately 10 months.

If only one crew is used to complete the work at both sites, then work will bestarted and completed at one Site before work at the other Site is begun. Thiswould increase the time needed to complete both Sites to approximately 18months."

Comment 16: Page 4-7, Section 4.2.1.5, Chemical Treatment and FutureDemolition - line 2 of the first full paragraph, "the slabs or walls would stillwould", remove the second would.

Action: The second "would" was removed in both reports.

Comment 17: Section 5.1.3, Cost Evaluation - Include future disposal costsin costs listed in this section.

Action: The words " and disposal" were added and the "and" before"material" was removed to the end of the second sentence in the CapitalCosts bullet in this section of both reports.

Comment 18: Section 5.2.1.3 Building Demolition and Disposal Alternative- Provide more information as to what provisions will be taken to controldust and storm water runoff. Also, indicate that the covered concrete dockalong the southwest side of the Ewing facility will be included in thedemolition and disposal alternative.

Action: The following paragraph covering both dust control and storm waterrunoff was added to both reports as the third paragraph of section 5.2.1.3:

"It is anticipated that a detailed work plan for the demolition of the buildingwill contain information on the type of control to be used for dust and stormwater runoff. Dust control may include misting, some form of partialenclosure, etc. The demolition contractor will be required to followapplicable storm water discharge and air emission regulations to controlstorm water discharges and air emissions."

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Mr. Paul RoemermanMay 9, 2000Page?

For the second point (Ewing report), the first sentence in section 5.2.1.3 waschanged to read "The Demolition and Disposal Alternative provides for thebuilding and concrete dock along the southwest side of the building to bedemolished and the building materials segregated based on PCBconcentrations." (The underlined portion has been added.)

Comment 19: Section 5.2.1.3.2, Implementability - Since theimplementability of this alternative is dependent on the cooperation of theadjacent owners of the Ewing facility, they should be contacted in apreliminary fashion to determine if their involvement would render thisalternative infeasible.

Action: Both adjacent property owners, Cargill and Morton-Meyer, havebeen contacted. Both have been provided copies of the SCR report.Common Counsel to the Steering Committee has offered to meet with bothneighbors and provide additional information or answer questions they mayhave. As of this date, neither has requested further information.

Comment 20: Figure 2-2 - Check hatching of in E$-F4 (sic). Were the areasalong the north side and south side of the building found clean in previoussampling? If not, these areas will need to be sampled during the removal.

Action: We have assumed that the grid reference should read E4-F4 and thatthe building being discussed is the Wyandotte building. We believe that thehatching in E4 and F4 are correct. The dotted line, which runs between theboundary of the grids numbered 3 and 4, represents a dock. Samples weretaken on the '/a wall this dock creates and their results were taken into accountwhen considering how E4 and F4 should be shaded.

The areas along the north and south sides of the building were excluded fromsampling due to inaccessibility issues. This was discussed with the USEPAduring the SCR. These areas include office and storage space and restrooms.

Comment 21: Figure 2-3 - Check hatching around the elevator and the twostairwells.

Action: This comment refers to the Wyandotte building. This comment wasdiscussed with Candice McGhee of MDNR. These areas were checked foraccuracy and consistency and the figures revised where appropriate.Additionally, the shading shown in the legend that refers to these areas has

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been corrected to match the shading shown on the figure. It has beenclarified that if a stairwell landing was found to be above 1 mg/kg, then thestairs leading to and from that landing will also be considered contaminated.The following text was added to section 2.4.4, paragraph 3, after sentence 5,in both reports: "The sample results from stairwell landings found to havePCB concentrations > 1 mg/kg, will be carried out to the stairs leading to andfrom the sampled landing."

Comment 22: Figure 2-4 - Check hatching for A2-A3, B1-C1, B7-C7, andF1-G1.

Action: This comment refers to the Wyandotte building. This comment wasdiscussed with Candice McGhee at MDNR and it was explained why thehatching is shown as it is. She agreed with us that it is correct as shown.

Comment 23: Figure 2-5 - Check hatching around the stairwells. Also, onFigures 2-6 and 2-7.

Action: This comment refers to the Wyandotte building. This comment wasdiscussed with Candice McGhee of MDNR. These areas were checked foraccuracy and consistency, and the figures revised as appropriate.Additionally, the shading shown in the legend that refers to these areas wascorrected to match the shading shown on the figure. It was clarified, asdescribed in the action to Comment 21, that if a stairwell landing was foundto be above 1 mg/kg, then the stairs leading to and from that landing will alsobe considered contaminated.

Comment 24: Figure 2-8 - Check hatching for H3-H4.

Action: This comment refers to the Wyandotte building. This comment wasdiscussed with Candice McGhee at MDNR and it was explained why thehatching is shown as it is. She agreed with us that it is correct as shown.

Based on conversations between Region VII and the Steering Committee, wehave reviewed the rail service east of the Ewing Street building. There is onetrack that serves at least one business beyond Cargill. While we feel it isunlikely excavation will require removal of this track, it is possible that it willbe necessary to interrupt service on that track for some period of time duringthe removal action. For that reason, we have included a cost allowance toprovide alternative transportation during that period of time.

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In addition, we have included a copy of MDNR's letter dated January 18,2000 concerning ARARs in Appendix C of the Wyandotte Street report.Based on our conversation with Ms. McGhee at MDNR, it is ourunderstanding that this letter was intended to provide the reader withadditional information rather than to suggest changes to our ARAR table.

We trust you will find these revisions resolve the issues raised in yourcomment letter. Should you have questions concerning these reports, pleasefeel free to contact me at [816] 822-3076.

Sincerely,

C. Hoffmlft,. P.E.Principal Engineer

Enclosure

cc: Distribution List

McDonnell


Distribution ListRobert BeckAdam Meek, Esq.John WoodyardRussell B. Selman, Esq.Scot Campbell, Esq.Donald J. PylesMichael Wilcken, Esq.Larry D. LinderLarry BlalockJoseph M. SimoneTimothy N. AthertonRichard StembergFrank Murphy, Esq.Michael W. Hastings, Esq.Harry SlagleGreig Siedor, Esq.Steven V. DaltonMark LautenschlagerDavid DooleyPatrick CraigTimothy D. Hoffman, Esq.

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May 10,2000

Candice McGheeMissouri Department of Natural ResourcesDivision of Environmental QualityHazardous Waste Program1738 E. Elm, Lower LevelJefferson City, Missouri 65101

PCBINC Engineering Evaluation and Cost AnalysisProject No. 96-293-4-009-PCBINC_______

Dear Candice:

Enclosed is a copy of the revised Engineering Evaluation/Cost Assessment report forthe PCB Treatment facility located at 2100 Wyandotte Street in Kansas City,Missouri, which has been submitted to USEPA on May 10, 2000.

If you have any questions, please call me at 816-822-3076

Sincerely,

C. Hoffinaif, P.E.Principal Engineer

JCH/ech.342

Enclosure

cc: Paul Roemerman (without enclosure)

9400 Ward ParkwayXonsof City, Missouri 64114 3319Jd816 333-9400fox. 816 333-3690www.bwnjmtrf.fom

May 10,2000

Daniel GravattKansas Department of Health and EnvironmentBureau of Environmental RemediationForbes FieldBuilding 740Topeka, KS 66620

PCBFNC Engineering Evaluation and Cost AnalysisProject No. 96-293-4-009-PCBINC

Dear Dan:

Enclosed is a copy of the revised Engineering Evaluation/Cost Assessment reportfor the PCB Treatment facility located at 45 South Ewing Street in Kansas City,Kansas, which has been submitted to USEPA on May 10, 2000.

If you have any questions, please call me at 816-822-3076

Wncerely,

C. Hoffinan, P.E.Principal Engineer

JCH/ech.344

Enclosure

cc: Paul Roemerman (without enclosure)

9400 Ward ParkwayKansas Qty, Missouri 64114-3319hi: 816 333-9400fax: 816 333-3690w*w.bumn>(d.iom

burns ^ mcdonndl may 9, 2000

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