memorandum gene gunn, chief to: year review of the ...• 1940-1941: land for weldon spring ordnance...

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION VII901 NORTH 5TH STREET

KANSAS CITY, KANSAS 66101 ID #:Brcak:__Jtl:._Q-

MEMORANDUM

Concurrence on the Weldon Spring Ordnance Works - Operable Unit 1

Tom Lorenz, Remedial Project ManagerFederal Facilities/Special Emphasis Branch

Gene Gunn, ChiefFederal Facilities/Special Emphasis Branch

Cecilia Tapia, DirectorSuperfund Division

SUBJECT:

FROM:

THRU:

TO:

The U.S. Army Corps of Engineers, Kansas City District (USAGE) conducted its five-

year review of the Former Weldon Spring Ordnance Works, Operable Unit 1: Soil and Pipeline.

The Draft Final Five-Year Review Report is attached. The Environmental Protection Agency

provided comments on the first draft which have been adequately addressed in this version.

Attachment

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SUPERFUND RECORDS

RECYCLE©PAPER COHTM-i «EC'CL£0 TBERS

US Army Corpsof Engineers®Kansas City District

FINAL

Five-Year Review Report

1st Five-Year Review Reportfor the

Former Weldon Spring Ordnance WorksOperable Unit 1: Soil and Pipeline

Weldon Spring, Missouri

March 2005

Prepared by:United States Army Corps of Engineers - Kansas City District

Kansas City, Missouri

RECEIVED

MAR 1 4 2005SUPERFUND DIVISION

LEAD AND SUPPORT AGENCY ACCEPTANCEOF THE FIVE YEAR REVIEW

FORMER WELDON SPRING ORDNANCE WORKS,WELDON MISSOURI

Signature Sheet for the fol lowing Five-Year Review for Weldon Spring Ordnance Works.

The United States Army has prepared the following Five-Year Review in accordancewith CERCLA, as amended. It is hereby approved by the Kansas City District andsubmitted for your review and approval.

Jl.Branch"ChieTr^TfvironrnentarProject Management DateU.S. Army Corps of EngineersKansas City District

Acronym List

ARARS Applicable or Relevant and Appropriate Requirements

Atlas Atlas Powder Company

BLRA Baseline Risk Assessment

CERCLA Comprehensive Environmental Response, Compensation and Liabil i ty Act

CERCLIS Comprehensive Environmental Response, Compensation, and LiabilityInformation System

COC(s) Chemicals of Concern

COPC(s) Chemicals of Potential Concern

cPAH Carcinogenic Polyaromatic Hydrocarbons

DNT Dinitrotoluene

DOE Department of Energy

ESD Explanation of Significant Differences

EPA Environmental Protection Agency

FLW Fort Leonard Wood

HQ Hazard Quotient

MDNR Missouri Department of Natural Resources

MDOC Missouri Department of Conservation

NPL National Priorities List

OSWER Office of Solid Waste and Emergency Response

OU1 Operable Unit 1: Soil and Pipeline

OU2 Operable Unit 2: Groundwater

PAH Polyaromatic Hydrocarbons

PCB Polychlorinated Biphenyls

RA Remedial Action

RfD Reference Dose

RI Remedial Investigation

ROD Record of Decision

Site Weldon Spring Ordnance Works

TBC To Be Considered

TCLP Toxicity Characteristic Leachate Procedure

TEF Toxic Equivalency Factor

TIS Transportable Incineration System

TNT Trinitrotoluene

USAGE United States Army Corps of Engineers

WSOW Weldon Spring Ordnance Works

WSSRAP Weldon Spring Site Remedial Action Project

WSTA Weldon Spring Training Area

Five-Year Review Summary FormSITE IDENTIFICATION

Site name (from WasteLAN): Former Weldon Spring Ordnance WorksEPA ID (from WasteLAN): MO5210021288Region: 7 [State: MO [City/County: Weldon Spring/St. Charles

m^ i ^^^^^^^^^^^^m^^^^^^^^^^^QNPL status: 0 Final D Deleted D Other (specify)Remediation status (chooseMultiple OUs?* D YES

all that apply)0 NO

: DUnder Construction DOperating 0 Complete[Construction Completion Date NA

Has site been put into reuse? 0 YES D NOREVIEW STATUS

Lead agency: D EPA D State D Tribe 0 Other Federal Agency (USAGE)Author name: US Army Corps of Engineers; Kansas City DistrictAuthor title: USAGE [Author Affiliation: Lead AgencyReview period:** 01/05/1998 to 01/05/2003Date(s) of site inspection; 11/07/2002 and 06/26/2003Type of Review:

Review number:

DDD

0 1 (first) D

Post-SARA D Pre-SARA D NPL-Removal onlyNon-NPL Remedial Action Site D NPL State/Tribe-leadRegional Discretion D Policy HStatutory

2 (second) D 3 (third) D Other (specify)Triggering action:D Actual RA Onsite Construction at OU# 0 Actual RA Start at OU#1D Construction Completion D Previous Five-Year Review ReportD Other (specify)Triggering action date (from WasteLAN): 01/05/1998Due date (five years after triggering action date): 01/05/2003

* ["OU" refers to operable unit.] [Although this site has multiple OUs, only OU1 is covered by this review.]** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]

Five-Year Review Summary Form, cont'd.

Issues:Closure of OU1 has been achieved, but OUI w i l l remain the subject of future 5-year Reviews due to theremaining contamination at depth at Tl 3.

Recommendations and Follow-up Actions:

Provide current WSTA property owner/user with assistance as needed for usabi l i ty determination of theWSTA with respect to OU1 COCs and remaining contamination at T13 to ensure that the users areadequately protected. Continue to complete future 5-Year Reviews ensuring that the remedy remainsprotective of human health and the environment and is functioning as designed.

Protectiveness Statement(s):The remedy is now complete and is determined to be protective. One area on the WSTA w i l l havecontamination remaining at depth. This area lies well within the fenceline of the WSTA and is thereforeunder restricted access. The area is identified as T13 and is in an area adjacent to lead grid 13T. Testpits were dug by USAGE personnel confirming surf icial contamination of TNT. Pangea was contractedto dig the contamination and perform verification sampling. The material is present at a depth of 10 feetor greater and is of limited lateral extent. There is l imited chance of exposure to the contamination dueto the fact that the remaining contamination is present at depths greater than construction activities wouldrequire disturbing. Remedial activities for this area, T13, were completed in August 2004. The resultshave been documented in the Final Remedial Action Report which has been reviewed and approvedby the regulatory agencies. These reports, combined with other required documentation, w i l l be providedto verify the closure of OU1 and confirm the status of human health and environment protectiveness at.theWSOW and WSTA. T13 w i l l be the subject of subsequent 5-year Reviews.

Other Comments:|None.

I. Introduction

This five-year review was conducted in accordance wi th the Comprehensive Five-Year ReviewGuidance, Office of Solid Waste and Emergency Response (OSWER) Directive 9355.7-03B-P(June 2001). This five-year review, conducted by USACE-KCD, was initiated in December 2002and was completed in September 2004. This document w i l l become part of the InformationRepository. The Information Repository is located at the St. Charles City-County LibraryDistrict, Middendorf/Kredell Branch. This review does not include detail on site history andbackground, as it is 'available in other documents available at t h i s same location. The purpose ofa five-year review is to ensure that a remedial action remains protective of human health and theenvironment and is functioning as designed. The beginning of the remedial action on OU1 is thetriggering action for this five-year review. The triggering action began on January 5, 1998.

The remedial action (RA) for Operable Unit 1 (OU1) has left the site in a condition suitable forunrestricted exposure and unl imited use, except for the area known as T13. Five-year reviewsw i l l be a statutory requirement due to remaining contamination at depth at T13.

This is the first five-year review for the Former Weldon Spring Ordnance Works (WSOW)(Site). Due to the size and complexity of the Site, this review is for OU1 only (soils andpipeline). Groundwater contamination is addressed under Operable Unit 2 (OU2). Agroundwater remedy has not been selected and is therefore not subject to review at this time.

Investigations leading to a supplemental Feasibility Study for OU2 have been completed.Placement of wells in support of these investigations was based upon the need to monitor thebenefits of the OU1 remedial action by placing wells downgradient of excavation areas and todefine the nature and extent of the groundwater contamination by placing wells in perimeterlocations on both the Weldon Spring Training Area (WSTA) and WSOW. Monitoring wellswere placed in key locations across the entire WSOW. Comprehensive assessment reports onthe status of groundwater contamination have been completed. These comprehensiveassessments, the supplemental Feasibility Study and Proposed Plan for Remedial Action for theGroundwater Operable Unit for the Weldon Spring Ordnance Works, have been added to theadministrative record and are accessible to the public. No additional information on the status ofOU2 is provided in this review.

II. Site Chronology

• 1940-1941: Land for Weldon Spring Ordnance Works obtained• 1941-1945: Facility operated by Atlas Powder Company (Atlas)• 1944: First clean up by Atlas: washing equipment with soda ash solution, steaming, flushing

with water, excavation and removal of contaminated soils, burning, and controlled flashing.• 1945-1946: Second clean-up by Atlas and U.S. Army Corps of Engineers using the same

decontamination procedures in 1944• 1946: Facility declared surplus property and ownership was transferred to the War Assets

Administration• 1949: War Assets Administration distributed a bulk of the acres to state and local jurisdictions

(leaving only the current WSTA and the U.S. Atomic Energy Commission's former

Page I ol' 17 Draf t -F ina l Five-Year ReviewFormer Weldon Spring Ordnance WorksWeldon Spring. Missouri

Uranium Feed Material Plant site under Federal Ownership; the Uranium Feed MaterialPlant is commonly referred to as the Chemical Plant Area).

• 1950 -1956: Third clean up is actually a group of three efforts that took place during the 1950s.General Services Administration (successor to the War Assets Administration) regradedand hauled soils from the TNT (Trinitrotoluene) lines and removed scrap materials. The226 acres transferred to the Atomic Energy Commission were decontaminated in 1955(removal of 28,250 cubic yards of contaminated soil and 21,500 linear feet of buried TNTwastewater pipeline from the area that had been TNT plants 1, 2, 3, and 4; 59 buildingswere burned and eight more structures were razed). Late in 1956, 136 buildings wereburned and 20 were dismantled and/or sold in a clean-up effort called Cox's Program.

• 1962-1963: Fourth clean-up by the U.S. Army Support Center in St. Louis who coordinatedwith the U.S. Army Corps of Engineers and ordnance experts for removal of equipmentfrom and demolishing of 23 buildings.

• 1965-1967: Fifth clean up involved the dismantling and shipping of the wastewaterincineration plants to another TNT facility. Also, transformers, utility poles, and electricaland communications cables were removed and 70 buildings were demolished.

• 1967: Seven miles of railroad track were removed and shipped to other installations.• 1988: The Army initiated a comprehensive Remedial Investigation (RI) of the WSTA portion

of the Site.• 1990: Site placed on the National Priorities List (NPL) .• 1990-1991: A companion RI was completed for the remainder of the WSOW (outside the

WSTA) after the entire site was placed on the NPL.• 1992-1993: Baseline Risk Assessment• 1993: Feasibility Study for OU1• 1993: Army released the Proposed Plan for the former WSOW OU1: Soils and Pipeline• 1996: Record of Decision for OU1• 1997: Site mobilization on December 15, 1997• 1998: Remedial action for OU1 initiated on January 5, 1998 (Weston) (as listed in CERCLIS)• 1999: Remedial action for OU1 suspended (Weston)• 2000: Draft Remedial Action Report for OU1 submitted (Weston)• 2000: Remedial action for OU1 resumed (Pangea)• 2001: Remedial action for OU1 completed (Pangea)• 2001: Draft Close-Out Report for OU1 submitted (Pangea)• 2002: Draft-Final Remedial Action Report for OU1 submitted to regulators (Weston)• 2002: Draft-Final Close-Out Report for OU1 submitted to regulators (Pangea)• 2002: Additional Contamination discovered (USACE/DOE)• 2003: Follow-up remedial action for OU1 initiated at T13 (Pangea)• 2004: Remedial action for OU1 at T13 completed (Pangea)• 2004: Draft; Final Remedial Action Report for OU1 submitted (Pangea)• 2004: Draft-Final; Final Remedial Action Report for OU1 submitted to regulators (Pangea)• 2004: Explanation of Significant Difference to the 1996 ROD (Record of Decision) submitted

for signature• 2004: Explanation of Significant Difference signed by USAGE, FLW, and EPA• 2004: Final Remedial Action Report for OU1 finalized; OU1 closure given by EPA

Page 2 of 17 Draft-Final Five-Year ReviewFormer Weldon Spring Ordnance WorksWeldon Spring, Missouri

III. Background

Physical Characteristics

The Former WSOW site is located in St. Charles County, Missouri about 30 miles west of St.Louis and about 14 miles southwest of the City of St. Charles. It is bisected by State Highway94, bounded on much of the north by U.S. Highway 40-61, and bounded on much of the south bythe Missouri River. The area of the Ordnance Works site during production was 17,232 acres.

Topography of the site is h i l l y , varying from gently roll ing in the north to rugged in the south.The location of the site is shown on Attachment 1 (Regional Map for Former Weldon SpringOrdnance Works).

Geology/Hydrogeology

The northern half of the site drains northeastward through a series of creeks and man-made lakesto Dardenne Creek, which is a tributary of the Mississippi River. The southern portion of the siteis more steeply sloped and heavily wooded, and drains southeastward into Little Femme OsageCreek and the Missouri River.

Three aquifers have been identified in the site area. They are the sand and gravel a l luv ium of theMississippi and Missouri Rivers and their tributaries, the shallow bedrock aquifer (Burlington-Keokuk and adjacent lower formations), and the deeper bedrock aquifer (St. Peter Formation),which is separated from the shallow bedrock aquifer by an aquitard. The shallow bedrockaquifer consists of the Burlington-Keokuk Formation (weathered and unweathered), the FernGlen Formation, and the Chouteau Group. The principal recharge to this aquifer is throughprecipitation inf i l t ra t ion from the overburden, from losing stream drainages, or from surfacewater impoundments. The aquitard consists of the Hannibal Formation, Sulphur Springs Group,Kimmswick Formation, Decorah Group, Plattin Formation, and Joachim Formation. The deeperbedrock aquifer is the St. Peter Formation. Recharge into the deep bedrock aquifer occurs wherethe bedrock units are near the surface or by leakage from the overlying shallow bedrock aquifer.However, the thickness of the confining unit and the low vertical flow velocities associated withthe overlying shallow aquifer would likely mitigate any significant contaminant migration to thedeeper aquifer on site.

Land and Resource Use

The Former-WSOW NPL site encompasses the WSTA, Busch Conservation Area, the WeldonSpring Conservation Area, a Missouri Department of Transportation Depot, Francis Howell HighSchool, Weldon Spring Heights, Former Chemical Plant Area, and the Missouri Research Park.The Former Chemical Plant Area is a separate NPL site known as the Weldon Spring SiteRemedial Action Project and is being addressed by the United States Department of Energy. Theremaining areas are addressed as part of the Former WSOW NPL site. Attachment 2 (Site Mapfor Former Weldon Spring Ordnance Works) shows the location of these properties.

Page 3 of 17 Draft-Final Five-Year ReviewFormer Weldon Spring Ordnance WorksWeldon Spring. Missouri

The land in the immediate vicinity of the site is currently undeveloped. Yet, the area to thenortheast is rapidly being developed into single-family and multi-family residential areas. Therehave been dramatic increases in population in recent years in nearby incorporated areas such asO'Fallon, St. Peters, and Cottleville. Although there are no residential properties on the landparcels where plant operations occurred on the Former-WSOW NPL site, based on current landuse, cleanup goals were set to protect potential future residents. Office buildings have been builtin Missouri Research Park. The Busch Wildlife and Weldon Spring Conservation Areas attractover 1,000,000 visitors per year for fishing, hunting, and nature studies. Natural resourcesinclude several heavily wooded areas, the most diversified flora of any part of the state,migratory bird refuge areas, 37 lakes, and numerous fishing ponds.

The WSTA is currently under ownership by Ft. Leonard Wood and is in use by the Army 89th

Regional Readiness Command as a training area. The WSTA's firing range is also used by localand federal law enforcement officials.

History of Contamination

The Former WSOW site was an explosives production facility that manufactured trinitrotoluene(TNT) and dinitrotoluene (DNT) for use in World War II. The facility was placed on standby in1944. While in standby, onsite contamination was discovered. There were several clean-upactions taken and investigations completed prior to the site being listed on the NPL.

Initial Response

There were several actions taken to reduce the extent of contamination prior to the placement ofthe site on the National Priorities List (NPL) in 1990. These events are identified in Section II,Site Chronology. These events are not related to the process established by CERCLA(Comprehensive Environmental Response Compensation and Liability Act) but significantlyreduced the potential for exposure to nitroaromatic contamination prior to the initiation of theremedial action in OU1. Additional detail on these activities is provided as part of the SiteBackground in the Final Remedial Investigation - Weldon Spring Training Area - Volume I (ITCorporation).

A Remedial Investigation was initiated in 1988. Before the investigation was completed, the sitewas placed on the NPL. Remedial action for the soil and pipeline began in 1998.

Basis for Taking Action

Two Remedial Investigations (RI) were conducted by U.S. Army Corps of Engineers (USAGE),one for the WSTA was initiated in 1988 and the other in 1993 for the rest of the WSOW. Thesetwo RIs were used to identify the types, quantities, and locations of contaminants in differentmedia throughout the entire Former WSOW area.

Chemicals that posed potentially unacceptable risks were designated as Chemicals of Concern(COCs), and Remediation Goals were identified for these COCs. Soils with concentrations of


TNT and DNT (Dinitrotoluene) that exceeded the risk based Remediation Goals requiredremediation:

2,4,6-TNT 57 ppm (10~6 risk, residential exposure)2,4- and 2,6-DNT 2.5 ppm (10~6 risk, residential exposure)

Soils contaminated by polychlorinated biphenyls (PCB) and polycyclic aromatic hydrocarbons(PAH) also exceeded Remediation Goals and required remediation:

Total PCBs 10 ppm (EPA PCB Spill Cleanup Policy)Total carcinogenic PAHs 10 ppm (10~6 risk on the WSTA)

It was determined that the pipeline only presented a safety-related risk and not a health-relatedrisk. The pipeline was removed and incinerated based on the non-quantified safety risk.

Lead was not found to pose a hazard to human health and the environment (See section 2.6 of theROD). However, it was found at many locations in the soils at the WSTA and in theConservation Areas in concentrations above those established to be protective for Superfundsites. The cleanup of lead at WSOW was based upon the EPA (Environmental ProtectionAgency) Interim Guidance on Establishing Soil Lead Cleanup Levels at Superfund Sites. Thiswas included as To Be Considered (TBC) material (guidance rather than regulation) duringdetermination of Applicable or Relevant and Appropriate Requirements (ARARs) for the site:

Lead 500 ppm (EPA Superfund Site Lead Policy)

The RI also included a groundwater investigation. This investigation showed that thegroundwater was contaminated with TNT and DNT. The Baseline Risk Assessment (BLRA)evaluated the groundwater contamination. The Army, EPA, and MDNR (Missouri Departmentof Natural Resources) agreed that the soil and groundwater would be addressed on separateschedules to permit accelerated clean up of the soil.

IV. Remedial Actions

Remedy Selection

On September 26, 1996, a ROD was signed to address OU1 (soils and pipeline). The selectedremedy was Rotary Kiln Incineration. The selected remedy involved excavation and thermaldestruction of nitroaromatic-contaminated soils and wooden pipeline. The remedy also providedfor the excavation and stabilization of the lead-contaminated soils that did not meet lead ToxicityCharacteristic Leachate Procedure (TCLP) requirements. After stabilization, the lead-contaminated soils and construction debris were to be placed in an on-site landfill. Section 2.11of the ROD (Documentation of Significant Changes), states that the Army will use the DOEWSSRAP storage cell rather than a separately constructed and maintained facility at WSOW forall specified landfill disposal. Because WSOW completely surrounds the DOE NPL site, use ofthis disposal cell is considered on-site disposal for purposes of CERCLA requirements. This cellis part of the Weldon Spring Site Remedial Action Project (WSSRAP) and is therefore subject to


its own five-year review and wi l l not be covered in t h i s report. An Explanation of Signif icantDifferences (ESD) was signed in 2004. This ESD addressed events that occurred dur ing theremedial action which were deemed significantly different , but did not fundamental ly alter theremedy.

This remedial action incorporated both treatment and containment technologies for remediationof soil and pipeline media at the Site. The remedy included incineration of nitroaromatics-contaminated soils and wooden pipeline, stabilization and on-site landfill of lead-contaminatedsoils, and landfi l l of construction debris separated from contaminated soils. The remedy alsoincluded the disposal of PAH and PCB (<500 ppm) contaminated soil in the DOE WSSRAPstorage cell. The DOE WSSRAP storage cell was selected rather than a separately constructedon-site landfil l . These technologies were selected to substantially reduce risks associated withthe contaminated materials that represented the principal threat at the site, and provided forpermanent destruction of the nitroaromatics contamination. Also, since the cleanup goals wereset to protect for residential exposures, no insti tutional controls were required. The actions ofthis remedy addressed the direct threat to human health and the environment by remediating thecontaminated soil and pipeline across the Site. Although not the primary goal of OU1, theselected remedy also eliminated a source of nitroaromatics to the groundwater.

Remedy Implementation

OU1 - Soil and Pipeline

In 1997, USAGE awarded a contract for remedial action to Roy F. Weston, Inc. (Weston). Atransportable incineration system (TIS) was selected for the remediation of WSOW OU1. Theremediation involved excavation and incineration of TNT/DNT contaminated pipelines and soils.Remediation also involved the stabilization of lead contaminated soils that failed the TCLP anddisposal of construction debris, separated from the contaminated soils, in the on-site landfi l l .Restoration of the affected areas was also included in the contract (backfill , regrading, seeding,etc.).

• Weston excavated 41,790 cubic yards of TNT/DNT- contaminated soils.• A total of 71,836 tons of pipeline material and associated TNT/DNT and lead co-

contaminated soils and debris were thermally treated.• Weston backfilled the excavations with 39,121 tons of treated ash, 2,500 cubic yards of

boiTOw soils, and 15,588 tons of top soil.• Approximately 3,000 linear feet of abandoned toluene pipelines were removed.• Weston also excavated a total of 10,325 cubic yards of lead-contaminated soils from WSTA

areas and Burning Ground 1. (Burning Ground 1 is southeast of the WSTA, but within theboundaries of the original WSOW property.)

Weston's contractual obligations were ful f i l led in 1999 and a second contractor was hired tocomplete the remaining tasks associated with the OU1 remedial action. Pangea Group, Inc.(Pangea) was contracted to remove waste stockpiled by Weston and perform additionalexcavation as needed. This waste was disposed of in the adjacent DOE WSSRAP storage cell.In 2000, Pangea was contracted to complete the Former WSOW project closure activities.

l';ige 6 of 17 Draft-Final Five-Year ReviewFormer Weldon Spring Ordnance WorksWeldon Spring, Missouri

• Approximately 23,756 cubic yards of the previously treated waste, contaminated soil, andmiscellaneous debris were transported from the Former WS'OW to the DOE WSSRAP storagecell.

• Pangea completed additional excavation and confirmation sampling activities at BurningGround 1 (approximately 2000 cubic yards).

• Approximately 10,086 cubic yards (post treatment volume) of soil containing levels ofDNT and/or lead required chemical stabilization. After stabilization, the soil was transportedto the DOE WSSRAP storage cell.

• In total, the quantity of material that was transported by Pangea to the DOE WSSRAPstorage cell was approximately 33,842 cubic yards.

In March 2003, the investigation of two remaining areas of possible contamination was initiatedby USAGE. Pangea Group, Inc. was contracted once again to complete the investigation of twoareas named T14 and T13. Throughout 2003 and 2004 Pangea completed the remainingremedial activities for closure of OU1.

• Pangea investigated and confirmed that contamination did not remain at T14.• Contamination was found to remain at T13 and during subsequent removals a clay tile pipe

impacted with off-spec TNT was discovered.• Approximately 1350 cubic yards of TNT and DNT contaminated soil was removed from

the T13 main excavation and disposed of at Peoria Disposal Company in Peoria, IL.• 189 pounds of TNT were removed from the 64-foot long clay t i le pipe. The TNT was

transported to and incinerated at the Onyx Facility in Sauget, IL.• Soil contamination did exist under the clay ti le pipe and 184 cubic yards of TNT and DNT

contaminated soil was removed from the pipeline excavation and disposed of at PeoriaDisposal Company.

• Contamination does remain at depth at both the main excavation and pipeline excavationlocations. Attachment 3 (Plan Diagrams of TNT/DNT Exceedances of Remediation Goals atT13) depicts the areas of remaining contamination.

• Attachments 4, 4a, and 4b depict areas where remedial actions occurred and illustrate wherecontamination has been left in place and those areas, which were remediated successfully.

V. Progress Since the Last Five-Year Review

This is the first five-year review for the Former WSOW.

Page 7 of 17 Draft-Final Five-Year ReviewFormer Weltlon Spring Ordnance WorksWelclon Spring. Missouri

VI. Five-Year Review Process

Administrative Components

The five-year review team members included USAGE, the Army Reserves, the United StatesEnvironmental Protection Agency (EPA), the Missouri Department of Natural Resources(MDNR), the Missouri Department of Conservation (MDOC), and members of the WeldonSpring community. This team was generated to provide a comprehensive evaluation of theWSOW OU1 remedial action. Preliminary research and investigation was completed byUSAGE. Other team members were added to facilitate completion of the review.

Document Review

• Remedial Investigation Report for Weldon Spring Ordnance Works, IT Corporation,November 1992

• Remedial Investigation Report for Weldon Spring Training Area, IT Corporation, March1993

• Baseline Risk Assessment Weldon Spring Ordnance Works, IT Corporation, May 1993• Feasibility Study Weldon Spring Ordnance Works, IT Corporation, July 1993• Record of Decision, USAGE, September 1996• Feasibility Study for Operational Unit-2, Argonne National Laboratory, December 1998• Final Remedial Action Report, Roy F. Weston Inc., February 2000 (rev. April 2002)• Final Operable Unit 1 Project Closure Closeout Report, Pangea Group Inc., September

2001 (rev. April 2002)• Final Remedial Action Report, Pangea Group Inc., September 2004 (rev. 4).

Data Review

Weston ,

Weston performed the soil excavation and the pipeline removal and incineration. Nearly 41,790cubic yards of contaminated soil was excavated and 71,836 tons of soils and debris werethermally treated. Remediation Goals were developed to be protective of potential futureresidential site use, based on a 30-year adult exposure via the soil ingestion exposure route.

The Remediation Goals for the excavation of contaminated soil were:

• 57 milligrams per kilogram (mg/kg) for TNT,• 2.5 mg/kg for 2,4-and 2,6-DNT,• 500 mg/kg for total lead,• 10 mg/kg for PCBs, and• 10 mg/kg for PAHs.


The incineration Remediation Goals were:• 57mg/kgforTNT,• 2.5 mg/kg for 2,4- and 2,6-DNT, and• 5 milligrams per liter (mg/L) for leachable lead, TCLP.

If the concentration of leachable lead exceeded 5 mg/L, stabilization of the material wasrequired. Verification the Remediation Goals were met is documented in the Final RA reportprovided by Weston.

PangeaAfter Weston demobilized, Pangea continued the remaining scoped work at the Site byperforming the necessary soil stabilization and disposal of approved materials (soil and debris) inthe DOE WSSRAP storage cell. Approximately 10,086 cubic yards of soil required stabilization.The Remediation Goals for the stabilization, by TCLP analysis are:

• 0.130 mg/L for leachable 2,4-DNT and• 5 mg/L for leachable lead.

Verification that the Remediation Goals were met is documented in the Final Closeout Reportsubmitted by Pangea. The Final Remedial Action Report documents the area (T13) wherecontamination has been left in place at depth. Attachment 2 and 4 through 4b show the remedialefforts that have met remediation goals and those where contamination above remediation goalshas been left in place.

Site Inspection

A site inspection was conducted on November 6, 2002. The site inspection was conducted byDave Nelson and Bill Empson, a Process Engineer and Civil Engineer with the USAGE. It wasdetermined that there have been no changes in the physical conditions of the site that wouldaffect the protectiveness of the remedy. The site had been restored (backfilled, graded, seeded,etc.) as part of the closeout activities of remedial action. The site was well vegetated with areasof dense trees and undergrowth. At the time of this inspection, construction activities associatedwith OU1 had been complete for approximately seventeen months. The areas identified in anAugust 2002 site visit were the only remaining areas that required additional investigation.

A follow-up site inspection was completed on June 26, 2003. The entire review team(representatives from the USAGE, Army Reserves, Restoration Advisory Board, MDNR, EPA,and the St. Charles County Department of Environmental Services) performed the inspection. Inthe meeting, interviews were conducted to determine an overall impression of team members onthe status of the site. Ten locations on the WSTA and WSOW were selected for visualinspection, based on input from the representatives of the review team. The status of the threesites 4W, 14W, and T13 identified in an August 2002 site visit was also verified. The rationalefor the selection of 4W relates to DOE boring activities during which TNT stained soil wasencountered. This soil was containerized. Test pits were dug around the monitoring well areaand visually screened for the presence of TNT. All soils from the test pits and borings werecontainerized in 55-gallon drums. These drums were transported to the WSTA and stored at

Page 9 ot" 17 Draft-Final Five-Year ReviewFormer Weldon Spring Ordnance WorksWeklon Spring, Missouri

T13. They were later disposed of in an off-site landfi l l . 14W was a previously remediated areaon the WSTA. Weston performed a substant ia l grid dig in the area. To the side of theexcavation is a drainage ditch. A representative from MDNR recalled seeing red stained soil inthis drainage area. Two test trenches in the area of concern were dug and field-tested usingWebster's Reagent. No further soil contamination was found. The trenches were backfilled andthe area closed. T13 is in an area adjacent to lead grid 13T. Test pits were dug by USAGEpersonnel confirming surficial contamination of TNT. Pangea was contracted to dig thecontamination and perform verification sampling. This dig advanced well beyond surficialcontamination. The main excavation at T13 was advanced to a terminal depth of 22 feet.Approximately 1534 cubic yards of TNT and DNT contaminated soil was removed and disposedof at an off-site subtitle C landf i l l . DNT contamination does remain at depth in the excavation.During the excavation a clay ti le pipe impacted with fibrous TNT was discovered. The TNT wasremoved and incinerated at an off-site faci l i ty. The pipeline was removed, decontaminated anddisposed of at the same subtitle C landf i l l as the soil. Soil contamination was encountered underthe pipeline and a pipeline excavation was advanced to remove the soil contamination. Thepipeline excavation was advanced in two sections. The first section had a terminal depth of 16feet and the second a terminal depth of 10 feet. TNT and DNT contamination does remain atdepth in one sidewall of the 16-foot section of excavation. Refer to Attachment 3.

Work at these three sites has been completed. The trip report for the site visi t conducted inAugust 2002 can be found at the back of th is report as attachment 5.

The stabilized lead soils and other material that did not meet the requirements for on-site backfillwere placed in the DOE WSSRAP storage cell as is indicated in the Section 2.11 of the ROD(Documentation of Significant Changes). Construction on the DOE WSSRAP storage cell wascompleted prior to the inspection. DOE has recently completed a five-year review that includesthe DOE WSSRAP storage cell. The DOE WSSRAP storage cell is not part of this five-yearreview.

Interviews

An interview was conducted on December 19, 2002 with Bil l Empson who was Civil Engineerfor the USAGE on the project during the remedial action of OU1. Mr. Empson provided adescription of the site before, during, and after the current stage of the OU1 remedial action. Healso gave a description of the operations during the OU1 remedial action. To date, severalsignificant issues associated with activities at the site have been identified and addressed. Theseissues are being documented in the BSD. Predicted site conditions and contamination basedupon earlier investigations at the Site differed from those encountered during actual remediationactivities. As a result, an increase in quanti ty and a variance in form of contamination fromwhat was identified in the ROD was remediated. The Army considers the differences to besignificant, but not fundamental to the remedy selected in the ROD, None of these issues hasaffected the protectiveness of the remedy.

The June 26th, 2003 Five-Year Review Meeting was structured to provide the review team anopportunity to discuss the status of OU1 and develop a site inspection plan. The overallconsensus of the team was that the project continues to move forward with good progress and

Page 10 of 17 Dra f t -F ina l Five-Year ReviewFormer Weldon Spring Ordnance WorksWeldon Spring, Missouri

that recent increases in the level of communication between all stakeholders has increased theawareness of each stakeholder to the status of OU1.

Further reporting or execution of interviews is not necessary. Sufficient information wascollected during the review of documents, site visits, and stakeholder meetings to provide anaccurate report on the status of OU1.

Community Involvement

An ad was printed in the St. Peters Journal on Sunday, August 17th, 2003 and Wednesday,August 20th, 2003 (Attachment 6). The ad was placed in the paper to notify the community thata five-year review was in progress. The notice identified the contaminants of concern at the siteand updated the.community on the status of the Remedial Action. The community wasencouraged to contribute to the review process. Two USAGE contacts were provided:

Mitchell Frazier, USAGE Kansas City District Public Affairs Officer, 816-983-3486William McFarland, WSOW Project Manager, 816-983-3360

Three radio stations were also contacted and asked to add an announcement of the five-yearreview to their announcement binder (Attachment 7). KMOX (1120 am, The Voice of St.Louis), KTRS (550 am, Talk Radio St. Louis), and KWMU (90.7 fm, In-Depth News &Intelligent Talk) were provided with an announcement. The radio stations could not guarantee orrecord the date and time of the announcements.

Upon final approval of this five-year review, an ad will be printed in the St. Peters Journal thatwill announce that the five-year review for the Former Weldon Spring Ordnance Works iscomplete. The ad will also provide information on the location of the Information Repositorywhere a copy of the review will be filed.

VII. Technical Assessment(The following questions are taken from EPA 's Comprehensive Five-Year Review Guidance,OSWER 9355.7-03B-P (June 2001))

Question A: Is the remedy functioning as intended by the decision documents?

Yes, the remedy is functioning as intended by the decision documents. The 1996-ROD calledfor the removal and incineration of TNT/DNT contaminated soil and pipeline. This remedialaction incorporated both treatment and containment technologies for remediation of soil andpipeline media at the Site. The remedy included incineration of contaminated soils and woodenpipeline. The remedy also included stabilization and disposal in the DOE WSSRAP storage cellof lead-contaminated soils, PAH and PCB contaminated soils, and construction debris separatedfrom contaminated soils. These technologies were selected to substantially reduce risksassociated with the contaminated materials that represented the principal threat at the site, andprovided for permanent destruction of the nitroaromatics, PAH, and PCB contamination. Theactions of this remedy addressed the direct threat to human health and the environment byremediating the contaminated soil and pipeline across the Site.

Page 11 of 17 Draft-Final Five-Year ReviewFormer Weldon Spring Ordnance WorksWeldon Spring, Missouri :

Less than one half of one percent of the total volume of soil that exceeded the RemediationGoals, per the ROD, remains. The remaining material is at depths of 10 feet or greater and islocated within the fenceline of the WSTA (Attachment 2 and 3).

An ESD has recently been signed and addresses actions that were determined to be significantlydifferent from the ROD. These differences include cost, project duration, quantity of material,use of the DOE WSSRAP storage cell for material that met the requirements for incineration butwas remediated after operation of the incinerator had been discontinued, and off-site disposal ofsmall quantities of waste at permitted facilities.

Question B: Are the exposure assumptions, toxicity data, clean-up levels, and remedial actionobjectives used at the time of the remedy still valid?

Yes. The exposure assumptions, toxicity data, clean-up levels, and remedial action objectivesused at the time of the remedy are still valid. The BLRA considered only recreational andoccupational exposures to soils at the site and addressed residential exposure only forgroundwater. However, the Remediation Goals selected in the ROD were based on a residentialscenario to allow future unrestricted use of the site. Risk-based Remediation Goals for 2,4,6-trinitrotoluene and 2,4- and 2,6-dinitrotoluene were developed for the ROD based on a IxlO'6

cancer risk to each chemical for an adult ingesting 100 mg of soil 350 days per year for 30 years.Dermal and inhalation exposures were considered to be insignificant, and the effects of exposureduring childhood in increasing carcinogenic risks were not considered. This basis for calculatingcleanup levels was, however, a reasonably standard choice at the time the Remediation Goalswere developed.

Current risk assessment practice would call for the resident to be considered as a child for 6years of the 30-year exposure and as an adult for the remaining 24 years. As a child, the residentwould have a lower body weight of 15 kg rather than the adult weight of 70 kg and would beassumed to ingest 200 mg of soil per day. Furthermore, both the child and adult resident wouldbe assumed to have dermal absorption of the chemicals and inhalation from fugitive dust.

Using current exposure factors in common use (USEPA, 2003), the risks associated with the2,4,6-TNT and 2,4- and 2,6-DNT Remediation Goals for a potential future resident are about3.5xlO"6per chemical. Although these risk levels exceed the IxlO"6 "normal point of departure"in setting risk-based cleanup levels, these risk levels for the chemicals individually and for thetotal risk posed by all the chemicals on the site still lie well within the 10"6 to 10"4 acceptable riskrange.

Furthermore, there are at this time no residents on the site (WSTA). Comparing the RemediationGoals with risk-based goals developed for an on-site worker (USEPA, 2003), the risk to workers,who would be the most exposed individuals on site, from 2,4,6-TNT is IxlO"6 while a mixture of2,4- and 2,6-DNT, both present at their Remediation Goals, would pose a cancer risk to workersof IxlO"6 per chemical.


Thus, although risk assessment methodology has changed, the Remediation Goals for 2,4,6-trinitrotoluene and 2,4- and 2,6-dinitrotoluene do provide adequate protection for workers andother receptors currently on the site and would continue to provide an acceptable level ofprotection even if the land use of the site changed to residential or unrestricted use.

The Remediation Goal for PCBs was set using a cleanup level of 10 mg/kg for unrestrictedaccess from the EPA Spill Cleanup Policy as an ARAR. This standard has not been changed andis considered adequately protective.

The Remediation Goal for lead was set at 500 mg/kg using the "EPA Interim Guidance forEstablishing Soil Lead Cleanup Levels at Superfund Sites" (OSWER Directive #9355.4-02) as aTBC. This guidance did not set 500 mg/kg as a firm level to be achieved, but recommended it asa screening level to consider the development of a cleanup level. Since it was anticipated thatmodeled cleanup levels higher than 500 mg/kg would have a degree of uncertainty that mightmake acceptance difficult, it was common practice at the time of the ROD to set lead cleanuplevels at the recommended 500 mg/kg level. Since that time, the recommended level to beginscreening has been lowered to 400 mg/kg. It should be noted that these screening levels weredeveloped with protection of an exposed residential child as the goal. Also, in lead riskassessment practice both the 500 and 400 mg/kg concentrations were intended to representaverage concentrations over the site rather than maximum concentrations permitted at a singlepoint.

The evaluation of lead toxicity is rather difficult, and risk decisions are based on models thatrelate the distribution of blood lead concentrations to the level of lead in soil and other mediarather than directly on the occurrence of toxic effects. The criterion for protection is based on ablood lead concentration of 10 micrograms per deciliter (fig/dL) set by the Centers for DiseaseControl. Because the models assume a geometric distribution of blood lead levels, a fraction ofpeople exposed to lead in soil at any level will be modeled as having blood leads in exceedanceof 10 ng/dL. The goal of the modeling is to determine a level that will be protective ofapproximately 95 percent of the people exposed. The difference between exposures to averageconcentrations of 400 and 500 mg/kg in soil is that while a slightly larger fraction of childrenexposed may have blood lead levels higher than 10 jag/dL most exposed children will still beadequately protected. When modeling is conducted for adults, such as the workers currentlyexpected to be present on site, concentrations higher than 500 mg/kg are obtained which areadequately protective.

Also, rather than treating the 500 mg/kg as an average soil lead concentration to be achievedduring remediation, soils containing 500 mg/kg or more of lead were removed. Leadcontamination in soils at WSOW tended to occur in "hot spots" surrounded by soil with lead atlower levels. With the removal of these elevated leads, the average concentration of lead in soilsremaining has been reduced to less than 400 mg/kg, providing adequate protection forunrestricted use..

The Remediation Goal for PAHs was based on an assumption in use at the time of the ROD that. all carcinogenic PAHs were equipotent with benzo(a)pyrene. A significant difference in cancerrisk methodology is a result of the introduction of the Toxic Equivalency Factor (TEF) approach


for PAHs. This decreases cancer risks due to most of the PAHs that were previously consideredequal in carcinogenic potency to benzo(a)pyrene. One PAH, benzo(g,h,i)perylene, has been re-classified to Class D - Not Classifiable as to Carcinogenicity. Since risks from cPAHs otherthan benzo(a)pyrene were thus overestimated by one or more orders of magnitude, cleanupsbased on the total cPAH concentrations should still be adequately protective.

Toxicity values for several of the chemicals of concern have been changed since the ROD wassigned. The effects of these changes in toxicity values in COCs have been examined todetermine their effects on the protectiveness of the remedy. These changes are summarized inTable 1 (Effects of Changes in Toxicity Factors).

TABLE 1EFFECTS OF CHANGES IN TOXICITY FACTORS

ORAL REFERENCE DOSES - NONCARCINOGENIC EFFECTS

Chemical

PCB Aroclor 1016PCBAroclorl254

PreviousValue

mg/kg/dayNLNL

Current Valuemg/kg/day

7.00E-052.00E-05

Reference

IRIS 2003IRIS 2003

IncreasedChemicalToxicity?

YesYes

IncreasedPotential

Risk?No1

No1

ORAL SLOPE FACTORS - CARCINOGENIC EFFECTS

Chemical

Benzo (a) anthraceneBenzo (b) fluorantheneBenzo (k) fluorantheneBenzo (g,h,i) peryleneChryseneIndeno (l,2,3-c,d) pyrene

PreviousValue

(mg/kg/day)"1

7.37.37.37.37.37.3

Current Value(mg/kg/day)"1

0.730.73

0.073Reclassified as D

0.00730.73

Reference

TEF1993TEF 1993TEF 1993IRIS 2003TEF 1993TEF 1993

IncreasedChemicalToxicity?

NoNoNoNoNoNo

IncreasedPotential

Risk?NoNoNoNoNoNo

1 Since PCB-contaminated soils with levels up to 10 mg/kg are covered with clean fill to prevent long-term contactconsidered for this Reference Dose, adverse non-cancer health effects are still unlikely.mg/kg/day = milligrams of substance consumed per kilogram of body weight per dayPCB = polychlorinated biphenylNL = not listedIRIS = Integrated Risk Information System(mg/kg/day)'1 = milligrams of substance consumed per kilogram of body weight per dayD = not classifiable as to human carcinogenicityTEF = Toxicity Equivalency Factor

Reference Doses for non-carcinogenic effects of the PCB products Aroclor 1016 and Aroclor1254 have been approved for IRIS since the ROD was signed. Although the Hazard Quotientsfor PCBs would exceed 1 for direct contact with PCBs at the cleanup level specified in the ROD,the remediation included coverage of any remaining PCB-contaminated soil with a sufficientlayer of clean fill to prevent direct contact.


As discussed earlier, the assessment of the cPAHs, considered COCs in the ROD, hassignificantly changed with the introduction of the Toxic Equivalency Factor (TEF) approach.Cancer risk estimates for many of the cPAHs that were previously considered equal incarcinogenic potency to benzo(a)pyrene have been decreased. One PAH, benzo(g,h,i)perylene,has been re-classified to Class D - Not Classifiable as to Carcinogenicity.

Land use has not changed since the ROD, but the Remediation Goals identified in the ROD werebased on residential land use, which is the most conservative use.

Prior to the incineration of soil on-site, a site-specific risk assessment was performed to ensurethat any toxic by-products produced by that operation would not pose unacceptable risks tosurrounding populations. No other components of the remedy are considered to have thepotential to. generate toxic by-products. .

Thus, the past risk evaluation still appears to be valid for current .industrial and recreational landuses and continues to meet the Remedial Action Objectives set forth in the ROD. The past riskevaluation is still protective for nitroaromatics, PAHs, lead and PCBs for unrestricted use.

Question C: Has any other information come to light that could call into question the .protectiveness of the remedy?

N o . • ' ; - . v . - ' - . ' . • • : • • .

Technical Assessment Summary

According to the data reviewed, the site inspection, and the,interviews, it has been determinedthat the remedy is functioning as intended by the ROD!

Page 15 of 17 Draft-Final Five-Year ReviewFormer Weldon Spring Ordnance WorksWeldon Spring, Missouri ,

VIII. Issues

Issue #

1

Issue

An area of contamination remains at T13

Affects Protectiveness(Y/N)

CurrentN

FutureY

IX. Recommendations and Follow-Up Actions

Issue#*

1

Recommendations/Follow-up Actions

Provide currentWSTA propertyowner/user with

updates on remedialactivities and

provide assistanceas needed for

usability of theWSTA with respect

to OU1 COCs

PartyResponsible

USACE/ArmyReserves

OversightAgency

NoneRequired

MilestoneDate

Ongoing

AffectsProtectiveness

(Y/N)Current

N

Future

Y

*Issue number refers to the table in Section VIII (Issues),

I'age 16 of 17 DrafVFinal Five-Year ReviewFormer Welclon Spring Ordnance WorksWeldon Spring, Missouri

X. Protectiveness Statement

The remedy is now complete and is determined to be protective. One area on the WSTA wil lhave contamination remaining at depth. This area lies well w i th in the fenceline of the WSTA andis therefore under restricted access. The area is identified as T13 and is in an area adjacent tolead grid 13T. Test pits were dug by USAGE personnel confirming su r f i c i a l contamination ofTNT. Pangea was contracted to dig the contamination and perform verification sampling. Thematerial is present at a depth of 10 feet or greater and is of limited lateral extent. There is limitedchance of exposure to the contamination due to the fact that the remaining contamination ispresent at depths greater than construction activities would require disturbing. RemedialActivi t ies for this area, T13, were completed in August 2004. The results have been documentedin the Final Remedial Action Report, which has been reviewed and approved by the regulatoryagencies. These reports, combined with other required documentation, w i l l be provided to verifythe closure of OU1 and confirm the status of human health and environment protectiveness at theWSOW and WSTA. T13 will be the subject of subsequent 5-year Reviews.

XI. Next Review

As a matter of policy, the next five-year review w i l l occur no later than five years following thedate of the signed EPA concurrence letter to this five-year. Although, the OU1 remedy is nowcomplete, OU1 5-Year Reviews w i l l be continued due to contamination left in place at depth atT13. 5-Year Reviews wi l l continue to evaluate the effectiveness of the remedy as it pertains tothe land use of T13.

Page 17 of 17 Draf t -Final Five-Year ReviewFormer Welclon Spring Ordnance WorksWeldon Spring. Missouri

CODo

Q.n>S CD_ cro -c5 Q..2 co

c i-0) 0) 0)

Unscanned Items

A map or maps that could not be scannedexist with this document

or as a documentTo view the maps, please contact the

Superfund Records Center

>ICD

253'OQ3o>O

H|

HW

CDa.

oCDO

fD

i&5'r-fo'

Oo

£U)

Exceedance Legend

| | Excavation Perimeter (No sidewall or floor excsedance)

Floor Exceedance (FS - @)

•Sidewall Exceedance (SW- Appro.ximatc Location of Clay-TilePipe before Remediation(Sec Phase 2 of 2 10 Ihc right)

Phase I of 2 - General Excavation Approximate Scale: 1 inch equals 10 Ted

Approximate Scale: 1 inch equals 7000 feel

Weldon Spring Training Area

Approximate Scale: I inch equals 30 feel

S\V - D

Phase 2 of 2 - Clay-tile Pipe Excavation

LocationFS-AIKS - A2K S - BFS-C

SW- ASW-BSW-CS W - D

GUIRemediation

Goal

Depth22'22'\<f221

If.' -22'KV-22'16' - 22'U)'- I61

-

Sample Result in nig/kgTNT

159.62

2.XX

4.53.07

7.724.2

57

2,4-DNT

3.33.62

ix.y1

4.02

13746.1

10.6

2.5

2,6-DNT

26.3

O.SI

5.58

9.85

3.5X

7.17

14.4

1.22

2.5

Scales provided are approximate and are to be used for general reference only. The U.S. Army Corps of Engineers is not responsible for the misuseof the information provided in these figures. All other sampling points from excavation sidewall and excavation floor met Remediation Goals.

Legend

• TNT grid remediated to below 57 ppm

• DNT grid remeidated to below 2.5 ppm

• TNT and DNT Contamination above 57 ppm and 2.5 ppm

AUGUST A. BUSCH MEMORIAL CONSERVATION AREA

BG02

BG03

DOE WELDON SPRJNG\\ ~SITE CHEMICAL

PLANT AREABO07

BG01• A

TNT Production Lines (with the exception of TNT line 6 and 3)Sample number is of the form x-T-* where 'V refers to the TNTline number and the "*" refers to the particular grid as follows: RGOS

"A" indicates mono-, bi-, and tri-house area *"B" indicates wash house and settling tank areas"C" ususally indicates tramways"D" indicates grainer house areas"E" usually indicates wastewater catch basins"F" and "G" usually indicate pipeline corridors or streambed

TNT Production Line 6 was sampled during the Law Environmental Investigation.BG refers to Burning GroundAreas designated x-L (such as "2L") indicate a laboratory building areaAreas designated x-S (such as "2S") indicate a Sellite AreaAreas designated x-G (such as "4G") indicate a wastewater treatment plantAreas designated L-x (such as "L6") indicate a lagoonThe area designated "3D" refers to the grainer house of TNT line 3Area 390G AND 90-1G refer to settling tanks associated with a wastewater treatment plant

Attachment 4Remediated Areas of TNT and DNT Contamination

and Areas Remaining above Remediation Goals for TNT and DNT

.B62

0 800 1,600 3.200 4,800 6,400iFeet

Legend• Lead Contamination Above 500 ppm and Grid Designation

*• Lead Contamination Below 500 ppm and Grid Designation

B24

B50

August A. Busch Memorial Conservation Area

BG01TNT Production Lines (with the exception of TNT line 6 and 3}

Sample number is of the form x-T-'where 'V refers to the TNTline number and the ""' refers to the particular grid as follows:

"A" indicates mono-, bi-. and tri-house area"B" indicates wash house and settling tank areas"C" ususally indicates tramways"D" indicates grainer house areas"E" usually indicates wastewater catch basins"F" and "G" usually indicate pipeline corridors or streambed

TNT Production Line 6 was sampled during the Law Environmental Investigation.BG refers to Burning GroundAreas designated x-L (such as "2L") indicate a laboratory building areaAreas designated x-S (such as "2S") indicate a Sellite AreaAreas designated x-G (such as "4G") indicate a wastewater treatment plantThe area designated "3D" refers to the grainer house of TNT line 3Area 390G AND 90-1G refer to settling tanks associated with a wastewater treatment plant

Attachment 4aAreas Remediated for Lead Contamination

During the Execution of the OU1 Remedial ActionAs Identified in the 1996 Record of Decision

Legend

*, . PAH Contamination Below 10 PPM and Grid Designation

• PCB Contamination Below 10 PPM and Grid Designation

August A. Busch Memorial Conservation Area

DOE Wcldon Spring \, Site Chemical .%

Plant Area /,"

TNT Production Lines (with the exception of TNT line 6 and 3) :

Sample number i s of the form x-T-* where "x" refers to the TNTline number and the """ refers to the particular grid as follows:

"A" indicates mono-, bi-, and tri-house area'13" indicates wash house and settling tank areas"C"ususally indicates tramways . . . ' • ,"D" indicates grainer house areas"E" usually indicates wastcwaler catch basins. _ >T" and "G" usually indicate pipeline corridors or streambed

TNT Production Line 6 was sampled during trie Law Environmental Investigation.BG refers to Burning Ground ' ,-,Areas designated x-L (such as "2L") indicate a laboratory building areaAreas designated x-S (such as "2S") indicate a Sellite AreaAreas designated x-G (such as "4G") indicate a wastewatcr treatment plantThe area designated "3D" refers to the grainer house of TNT line 3Area 390G AND 90- 1G refer to settling tanks'associated with a wastewater treatment plant

y Attachment 4b

Areas Remeditaed for PCB and PAH ContaminationDuring the Execution of the OU1 Remedial Action

As Identified in the 1996 Record of Decision

Attachment 5Pages 2 & 3

Attachment 5

Trip Report: Former Weldon Spring Ordnance Works, Weldon Spring, MO.Date: August 14-16, 2002RE: Delineation of TNT Soils and Observation of Monitoring Well Installation ActivitiesWeather Conditions: Moderate to high temperatures (High 60's to low 90's° Fahrenheit)

Personnel In Attendance At Trenching Activities

Brad Vann - USACE-NWK (Geologist)Stefanie Voss - USACE-NWK (Geologic Engineer - Intern)Jason L'Ecuyer - USACE-NWK (Chemical Engineer - Intern)Tom Lorenz - USEPA Region VII (Remedial Project Manager)Jim Harris - Missouri Department of Natural Resources (OSC)Dan Marquis - USACE-NWK (Driller and Equipment Operator)Mike Cooney - USACE-NWK (Driller and Equipment Operator)Tony Cherry - USACE-NWK (Driller Helper)Coen Bauders - USACE-NWK (Field Geologist)

Day Two - August 15, 2002

07:57 hrs: Moved to the T13 area (suspected TNT soils location near MWS16) (Map1). Set up sampling points on a grid-based system. The grid consisted of one N-Sline 60' feet long intersected by three W-E lines 40' feet long (Figure 1). Each linewas broken down into 5-feet increments for sample collection. Sampling wasperformed with a simple spade shovel since the contaminated soil horizon wasbetween 2-4" inches below grade. Personnel hand dug all test pits (approximately 2'x 2' x 6") and qualitatively evaluated field soils using the Webster's Solution Test(see attached Photograph Log for visual details).

Equipment used for Webster's Solution Test:

• 2 Eye dropper bottles labeled (one for Sodium Hydroxide (NaOH) and the other forsolvent - 15-30ml each)

• One package of cone-shaped water cooler cups or plastic sample trays• One heavy-duty stainless-steel spoon• Distilled water and soap solution for decontamination• Plastic Bag for containing used cups and gloves

Directions for Webster's Solution Test:

• Collect approximately one-quarter teaspoon of suspect soil and put in bottom of cup• Add a few drops of solvent to the cup (acetone works well, but methanol or ethanol will

also work - for this event we used methanol). This action makes the nitrotoluenecompound miscible in water.

• Mix completely by swirling the material in the cup• Add a few drops of NaOH

• Watch and record the reaction1

This report is an update/modification of the original report submitted by Mr. Brad Vann. Information not relevant to Tl 3 has beenremoved. Although this report does not reflect the entire effort of these trips, all of the information related toT13 has been retained.

The fol lowing are the test locations of each test pit (TP#), and results us ing theWebster's Solution test for TNT soils and testing procedure (Figure 1):

North-South Line #1 (NS1 - Diskette #1 photographs 1 and 2)TP1 - Did not excavate further south due to two non-detects (TP2 and 3)TP2- Negative for TNT SoilsTP3- Negative for TNT SoilsTP4 - Positive for TNT Soils (Diskette #1, photographs 5 and 6)TP5 - Positive for TNT Soils (Diskette #1, photographs 3 and 4)TP6 - Negative for TNT SoilsTP7 - Negative for TNT SoilsTP8 - Negative for TNT SoilsTP9 - Did not excavate further north due to three non-detects (TP6-8)TP10 - Did not excavate further north due to three non-detects (TP6-8)TP11 - Did not excavate further north due to three non-detects (TP6-8)TP12 - Did not excavate further north due to three non-detects (TP6-8)

Note1: A positive reaction tu rns the l iquid blood red in color. High concentrations wi l l result in a darker purple color. Pureproduct may result in a black color. This test is qual i ta t ive and not quant i ta t ive . If samples arc positive then add i t iona llaboratory testing wi l l be required during the removal action. All excavation (size of area, location, etc.) and samplingresults w i l l be documented in the field notebook. The USAGE PM wi l l be notified of any positive TNT contaminated soilencounters (via cell phone) du r ing the same field day. This test was also Held calibrated or tested on known TNT soils atthe site and worked very well lor the qual i ta t ive identif icat ion.

West-East Line #1 (NS1 - Diskette #1 photographs 1)TP1 - Negative for TNT SoilsTP2 - Rock and Concrete from old Acid Tanks, could not excavateTP3 - Rock and Concrete from old Acid Tanks, could not excavateTP4- Negative for TNT SoilsTP5 - Negative for TNT SoilsTP6 - Did not excavate further west due to two non-detects (TP4 and 5)TP7 - Did not excavate further west due to two non-detects (TP4 and 5)TP8 - Did not excavate further west due to two non-detects (TP4 and 5)

Note: Soils outside of contaminated area are clearly different than wi thincontaminated zone. TNT soils are dark and mixed with significant quantities offine to coarse gravel. Soils beyond the contaminated zone (laterally andvertically) are clean, l ight to medium brown, s i l ty lean clay (some natural organicmaterials in the upper 2-3" inch layer.

12:15 Returned to T13 location and continued wi th delineation. We set up two moresampling lines (WYE #2 and W/E #3 - Diskette #2 photographs 1-4). Note: Mr. TomLorenz from the USEPA stopped by the site between 13:07 and 13:22 hrs to check onprogress.

West-East Line #2 (NS1 - Diskette #2 photograph 1)TP1 - Negative for TNT SoilsTP2 - Negative for TNT SoilsTP3- Negative for TNT SoilsTP4 - Positive for TNT Soils (Diskette #1,.photographs 7 and 8)

This report is an update/modification of the or iginal report submitted by Mr Urad V n n n . Informat ion not relevant t oTI3 has beenremoved. Although this report does not relied the entire effort of these trips, all of the in fo rmat ion related toT13 has been retained.

TP5 - Positive for TNT Soils (intercepted southern edge of original TPJ , see sitetrip report dated August 14-16, 2002 for GPS data)TP6 - Negative for TNT SoilsTP7 - Negative for TNT SoilsTP8 - Did not excavate further west due to two non-detects (TP6 and 7)

West-East Line #3 (NS1 - Diskette #2 photographs 2 and 3)TP1 - Negative for TNT SoilsTP2- Negative for TNT SoilsTP3 - Negative for TNT SoilsTP4- Negative for TNT SoilsTP5 - Positive for TNT Soils (Diskette #1, photographs 9 and 10)TP6 - Negative for TNT SoilsTP7 - Negative for TNT SoilsTP8 - Did not excavate further west due to two non-detects (TP6 and 7)

Note: Marked all positive hits on the ground with survey paint for clear v i s ib i l i ty(Diskette #1, photographs 11 and 12).

14:35 hrs: Based on the results of the test pits, TNT contaminated soil does not extendbeyond N/S-Line #1 between TP3 and TP10 (35' feet in length), W/E Line #2between TP3 and TP7 (20' feet in length), and W/E-Line #3 between TP3 and TP7(20' feet in length). Depth of contaminated soil does not exceed 4" inches. Based onthese observations, I recommend a soil removal action for an area measuring 35' feetx 20' feet horizontal ly and 6" inches in depth (approximately 350 cubic feet orapproximately 13 cubic yards).

Day Three - August 16, 2002

07:45 hrs: I went back to T13 with our Interns to measure the site and construct adetailed excavation map.

END OF TRIP LOG AS RECORDED BY BRAD VANN PROJECT GEOLOGIST

This report is an update/modification of the or ig ina l report submitted by Mr. Brad Vann. In fo rmat ion not relevant t o T I 3 has beenremoved. Although this report does not reflect the entire effort of these trips, all of the information related loTI3 has been retained

PHOTOGRAPH LOG:

Diskette One - T13 Excavation Area

Photograph one (Facing West): W/E Line #1. Flag pins areset every five feet and N/S Line #1 can be seen just behind the55-eallon drum.

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Photograph two (Facing North): N/S Line #1. Flag pins areset every five feet and W/E Line #1 can be seen just behindthe 55-gallon drum.

Photograph three: TNT contaminated soils showing a positive(red color) reaction using the Webster's Solution field test.Reddish soils are also clearly visible on the ground sample andin the excavation of N/S Line #1 TP5*.

Photograph four: Details of reddish soils that are clearlyvisible in the excavation of N/S Line #1 TP5. TNT soilhorizon lies between 2-4 inches below ground surface. Note:the gravel mixed in with the soil, which is typical for eachpositive area.

This report is an update/modification of the original report submitted by Mr. Brad Vann. Information not relevant to TI3 has been removed. Although this report doesnot reflect the entire effort of these trips, all of the information related to T13 has been retained.

Photograph five: TNT contaminated soils showing a positive(red color) reaction using the Webster's Solution field test.Reddish soils are also clearly visible on the ground sample andin the excavation of N/S Line #1 TP4.

Photograph seven: TNT contaminated soils showing apositive (red color) reaction using the Webster's Solution fieldtest. Reddish soils are also clearly visible on the groundsample and in the excavation of W/E Line #2 TP4.

Photograph six: Details of reddish soils that are clearly visiblein the excavation of N/S Line #1 TP4. TNT soil horizon liesbetween 2-4 inches below ground surface.

Photograph eight: Details of reddish soils that are clearlyvisible in the excavation of W/E Line #2 TP4. TNT soilhorizon lies between 2-4 inches below ground surface.

This report is an update/modification of the original report submitted by Mr. Brad Vann. Information not relevant to Tl 3 has been removed. Although this report doesnot reflect the entire effort of these trips, all of the information related to T13 has been retained.

Photograph nine: TNT contaminated soils showing a positive(red color) reaction using the Webster's Solution field test.Reddish soils are also clearly visible on the ground sample andin the excavation of W/E Line #3 TP5.

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Photograph ten: Details of reddish soils that are clearly visiblein the excavation of W/E Line #3 TP5. TNT soil horizon liesbetween 2-4 inches below ground surface.

Photograph eleven (Facing North): Looking parallel to N/SLine #1 at the finished sampling grid. W/E Lines 1-3 areaclearly visible in numerical order (starting in the foreground).Positive areas are marked with survey paint for visibility.

Photograph twelve (Facing South): Looking parallel to N/SLine #1 (W/E Line #3 is in foreground). Positive detects weremarked with a circle and X. Test pits 1 and 2 from theprevious site visit (29-30 July, 2002) are also visible. Test Pit1 is in the foreground to the left and outlined with markingpaint. Test Pit 2 is in the right-hand center portion of thephotograph and also outlined with marking paint. The othermarked areas are N/S Line#l - TP4 and TP5 and W/E Line #3-TP5.

This report is an update/modification of the original report submitted by Mr. Brad Vann. Information not relevant toT13 has been removed. Although this report doesnot reflect the entire effort of these trips, all of the information related to T13 has been retained. ,

Diskette Two - Excavation Area on West End ofWeldon Spring (T13)

Photograph one (Facing East): Looking parallel to W/E Line#2. Test Pit 1, from the July site visit, is in the foreground tothe left and outlined with marking paint. The other markedareas are N/S Line#l - TP5 and W/E Line #2 - TP4.

Photograph two (Facing East): Looking parallel to W/E Line#3. Test Pit 1, from the July site visit, is in just after the lineintersection and outlined with marking paint. The othermarked area is W/E Line #3 - TP5.

Photograph three (Facing West): Looking parallel to W/ELines 1-3 (terminate at survey lathes). Both concretefoundations are clearly visible in the vegetation.

Photograph four (Facing North): Parallel to the southern mostconcrete foundation (covered by vegetation). W/E Line #1 atTP3 in also pictured.

END OF PHOTOGRAPH LOG

This report is an update/modification of the original report submitted by Mr. Brad Vann. Information not relevant t o T I 3 has been removed. Although this report doesnot reflect the entire effort of these trips, all of the information related to T13 has been retained.

Site Map

Map 1: Location of TNT site (adjacent to lead grid T13)

Site Fieure from Field Notebook -•' ' ' ' '

Figure 1: Location of TNT based on 5:foot grid delineation on one bisecting N/S line and three transecting W/E Lines.

This report is an update/modification of the original report submitted by Mr. Brad Vann. Information not relevant to Tl 3 has been removed. Although this report doesnot reflect the entire effort of these trips, all of the information related to T13 has been retained.

ATTACHMENT 6

U.S. ARMY CORPS OF ENGINEERSFORMER WELDON SPRING ORDNANCE WORKS

ST. CHARLES COUNTY, MO

PUBLIC NOTICE5 Year Review in Progress

The U.S. Army Corps of Engineers, Kansas City District, is currently conducting a 5-year

review of the on going efforts to clean-up the soils at the Operational Unit 1 site of the

Former Weldon Spring Ordnance Works. The purpose of a five-year review is to ensure

that a remedial action remains protective of public health and the environment and that it

is also continuing to function as designed. The Record of Decision called for the removal

and incineration of TNT/DNT contaminated soil and pipeline and the stabilization of lead

contaminated soil. .The goals have been met and verified for the contaminants lead, PCBs

and PAHs. The Remedial Action for TNT and DNT should be completed by the autumn

of 2003.

The scheduled completion date for the 5-year review is September 30th, 2003.

The community is encouraged to contribute to the review process by contacting the

Public Affairs Officer, Mitchell Frazier, at 816-983-3486 or the Project Manager,

William McFarland, at 816-983-3360.

ATTACHMENT 7

U.S. ARMY CORPS OF ENGINEERSFORMER WELDON SPRING ORDNANCE WORKS

ST. CHARLES COUNTY, MO

PUBLIC NOTICE5 Year Review in Progress

The U.S. Army Corps of Engineers, Kansas City District, is currently conducting a 5-year

review of the on going efforts to clean-up the soils at the Operational Unit 1 site of the

Former Weldon Spring Ordnance Works. The purpose of a five-year review is to ensure

that a remedial action remains protective of public health and the environment and that it

is also continuing to function as it was designed.

The community is encouraged to contribute to the review process by contacting the

Public Affairs Officer, Mitchell Frazier, at 816-983-3486 or the Project Manager,

William McFarland, at 816-983-3360.

memorandum gene gunn, chief to: year review of the ...• 1940-1941: land for weldon spring ordnance...

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