D r a f t R e p o r t

Remedial Action Plan

Former Nelsen Wire/Prologis Property 1060 East Irving Park Road, Chicago, Illinois

Prepared for

Illinois Environmental Protection Agency On Behalf of

City of Chicago

April 2013

Prepared by:

BPC Airport Partners

iii

Executive Summary

This Remedial Action Plan (RAP) prepared by BPC Airport Partners on behalf of the City of Chicago describes the proposed remedy and evaluates its ability and effectiveness to achieve the remediation objectives approved for the remediation site, which was formerly located at 1060 East Irving Park Road in Bensenville, Illinois, and was annexed by the City of Chicago for the expansion of O’Hare International Airport. The property occupies 24.098 acres of land, which is currently vacant. This property was enrolled in the Site Remediation Program (SRP) in 1996 by Nelsen Steel and Wire Inc. and received a No Further Remediation (NFR) determination in 1997. The Illinois Environmental Protection Agency (IEPA) Bureau of Land identification number for the site is 0314145005.

The IEPA-approved remedy for the site in 1997 consisted of limiting the use of the property to industrial/commercial, a prohibition on the installation of potable water wells, the installation and maintenance of an engineered barrier above portions of the site, and a construction worker health and safety plan in areas of the property that exceed industrial/commercial or construction worker ingestion remediation objectives for polycyclic aromatic hydrocarbons (PAHs) and lead. The Prologis Business Park was developed on the property after 1997 with these remedial actions implemented. At that time, the property was occupied by three warehouse and distribution buildings, asphalt parking, and a stormwater retention pond.

The City of Chicago purchased and annexed the property in 2010 and plans to develop the site with a runway and the relocated Bensenville Ditch. The City of Chicago re-enrolled the property in the IEPA SRP in 2010 to develop and obtain approval for its site management/ remediation plans as the City develops the property for airport use, and ultimately obtains a revised comprehensive NFR letter.

The major components of the remedial action modifications consist of:

Restricting land use to industrial/commercial.

Development of Tier 3 remediation objectives for lead that indicate no offsite migration of lead above the TACO Class I groundwater standard at the property boundary. Consolidating soils containing PAH and lead concentrations, which exceed Remediation Objectives (ROs) in an approved soil management zone (SMZ).

Covering soil that exceeds ingestion ROs with an approved engineered barrier.

Prohibiting site-specific groundwater use by implementing the City of Chicago IEPA-approved groundwater ordinance and memorandum of understanding (MOU).

Notifying construction workers for subsurface work in impacted areas.

Onsite exceedances of the soil component of the groundwater ingestion exposure route values at the property will be excluded by preventing the use of site groundwater for consumptive purposes in accordance with the IEPA-approved City of Chicago groundwater use ordinance and MOU, as outlined in 35 IAC Part 742.1015.

REMEDIAL ACTION PLAN

iv

A construction worker notification will be recorded with the property deed as part of the NFR to alert personnel performing subsurface work to use caution and develop a health and safety plan to reduce ingestion exposure to soil constituents.

The proposed schedule for RAP implementation and completion reporting with assumptions is as follows:

Schedule Activity

May 2013 Initiate area engineered barrier placement

July 2013 Complete engineered barrier placement

90 days from completion of confirmation sampling, barrier placement and site restoration

Submit draft RACR documenting completion of the remedial action

60 to 120 days from submittal of final RACR (timeframe depends on IEPA backlog)

Obtain comprehensive NFR from IEPA

v

Contents

Executive Summary .......................................................................................................................... iii Contents ................................................................................................................................................ v Acronyms and Abbreviations ....................................................................................................... vii  Site Background .............................................................................................................................. 1-1 

1.1  Site Description ................................................................................................................. 1-2 1.2  Comprehensive Site Investigation ................................................................................. 1-2 1.3  Path Forward .................................................................................................................... 1-3 

Remedial Action Plan .................................................................................................................... 2-1 2.1  Statement of Remedial Objectives ................................................................................. 2-1 2.2  Proposed Remedial Action Approach ........................................................................... 2-2 

2.2.1  Engineered Barrier Installation ......................................................................... 2-3 2.2.2  Proposed Soil Management Zone ..................................................................... 2-4 2.2.3  Additional Closure Requirements .................................................................... 2-4 2.2.4  Schedule ................................................................................................................ 2-4 

Conclusions ..................................................................................................................................... 3-1  References ........................................................................................................................................ 4-1  Appendices

A City of Chicago Groundwater Use Ordinance and Memorandum of Understanding B Tier 3 Evaluation for Lead C Bentomat CLT Technical Specifications Tables

1 Soil Remediation Objectives with a Comparison to the Highest Measured Soil Concentrations

Figures

1 Property Location Map 2 Facility Layout 3 Cut and Fill Diagram and Proposed Soil Management Zone Location 4 Engineered Barrier and Construction Worker Notification Locations

vii

Acronyms and Abbreviations

bgs below ground surface

Clow James B. Clow & Sons Foundry

COC constituent of concern

CSI comprehensive site investigation

CSIR Comprehensive Site Investigation Report

ESA environmental site assessment

GRO groundwater remediation objective

IAC Illinois Administrative Code

IEPA Illinois Environmental Protection Agency

mg/kg milligrams per kilogram

mg/L milligrams per liter

MOU Memorandum of Understanding

NFR No Further Remediation

NRO no remediation objective

PAH polycyclic aromatic hydrocarbon

RACR Remedial Action Completion Report

RAP Remedial Action Plan

REC recognized environmental condition

RO remediation objective

ROR Remediation Objectives Report

SMZ soil management zone

SPLP Synthetic Precipitation Leaching Procedure

SRP Site Remediation Program

TACO Tiered Approach to Corrective Action Objectives

1-1

SECTION 1

Site Background

The property occupies 24.098 acres of land, which is currently vacant. This property was enrolled in the SRP in 1996 by Nelsen Steel and Wire Inc. and received an NFR in 1997. The IEPA Bureau of Land identification number for the site is 0314145005. The remediation site in 1997 consisted of 36.135 acres of land, of which, the northern 24.098 acres is included in this updated SRP enrollment. The southern 12.037 acres will be transferred to the Union Pacific Railroad and the Illinois Department of Transportation, and these new property owners are not enrolling their portions of the property in the SRP.

The earliest known development at the site was indicated in a 1959 Sanborn Fire Insurance map that showed the property occupied by the James B. Clow & Sons foundry (Clow). Prior to this time, the property was used for agricultural purposes. The Clow operations included a blast heater, core making, dielectric core oven, sand mixing and ladling, pipe casting, annealing furnaces and tar dipping. In addition, the fire insurance map shows a 110,000-gallon fuel oil aboveground storage tank and a 1,000-gallon gasoline underground storage tank on the southern portion of the property.

Nelsen Wire purchased the property in 1976 and produced cold heading, recessed hood, socket head, bearing and scrapless nut quality steel. The manufacturing process included pickling, annealing, repickling and coating of steel rod and wire drawing. Nelsen Wire ceased operation in 1991. Several soil and groundwater investigations were conducted between 1991 and 1996 to characterize and delineate the recognized environmental conditions (RECs) that were encountered in the 1991 Phase I Environmental Site Assessment (ESA) for the property. According to the 1991 Phase I ESA, the underground storage tank on the adjacent property was removed some time prior to 1991. All aboveground structures on the property were demolished in the summer of 1996. The 1991 through 1996 soil and groundwater investigation methodology and results were reported in the Site Investigation and Remedial Objectives Report, Nelsen Steel & Wire Co., Inc. Bensenville, IL, submitted by Environmental Resources Management to IEPA in 1997.

Prologis Business Park was developed on the property after 1997. The property was occupied by three warehouse and distribution buildings, asphalt parking and a stormwater retention pond. The developers of the Prologis property covered the two known areas of industrial/commercial soil ingestion exceedances with engineered barriers that were approved by IEPA in the RAP.

The Prologis operations ended in November 2009. A Phase I ESA was performed in December 2009. No RECs were identified from the onsite Prologis operations. The RECs were identified on the adjacent properties to the west and to the south. At the time of the Phase I ESA inspection, all buildings were vacant. A comprehensive site investigation (CSI) was performed by CH2M HILL in October 2010. At the time of the CSI, all aboveground structures from the Prologis operation had been removed from the site.

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1-2

A detailed discussion of the historical practices at the site is included in the Comprehensive Site Investigation Report / Remediation Objectives Report (CSIR/ROR; BPC Airport Partners), which IEPA approved on March 25, 2011. Additional soil and groundwater sampling was performed at the property in 2010 as part of this investigation to address the RECs identified on the adjacent property in the 2009 Phase I ESA report (Environmental Design International, 2009) and to provide an update to the 1996 investigation. Information gathered during these investigations was used to determine the extent of subsurface impacts at the property above the Tier 1 Tiered Approach to Corrective Action Objectives (TACO) ROs listed in 35 Illinois Administrative Code (IAC) Part 742. This information was used to develop site-specific ROs and this RAP.

1.1 Site Description The property is located in Cook County in northeast Illinois. Figure 1 shows the general location of the property with respect to the surrounding geography. Figure 2 shows the current layout of the property, including existing building pads and surrounding properties. The official addresses of the former buildings were 85, 95 and 105 Division Street, Bensenville, Illinois.

Directly west of the property, west of Division Street, were three additional Prologis parcels. Although these parcels were also part of the Prologis property, they are not part of the former Nelsen Wire property. Therefore, the parcels are not included in the remediation site boundary. These parcels are considered adjacent parcels. Irving Park Road and O’Hare International Airport are located directly north of the subject property. An undeveloped field, railroad tracks and O’Hare International Airport are located east of the property. The future Irving Park Road (under construction), a railroad embankment, Celli Trucking and a railroad-switching yard are located to the south.

The City of Chicago purchased and annexed the property and plans to develop the site with a runway, a taxiway the relocated Bensenville Ditch. The City of Chicago re-enrolled the property in the IEPA SRP to develop and obtain approval for its site management/ remediation plans as the City develops the property for airport use, and ultimately obtain a comprehensive NFR letter. The property was re-enrolled into the SRP on April 12, 2010.

With the exception of the Bensenville Ditch, upon the completion of the construction of the improvements for airport use in 2014, the property will be raised by 10 to 20 feet by importing clean fill meeting industrial/commercial remediation objectives. A runway will be constructed on top of this clean structural fill on the northern half of the site and the southern half of the site will be landscaped. The cut and fill diagram is shown in Figure 3.

1.2 Comprehensive Site Investigation The CSIR for this property detailing the procedures and findings of the historic and current investigations was submitted to IEPA in February 2011. The report, which was approved by IEPA in March 2011, stated that a RAP would be developed for this property following IEPA approval of the CSIR/ROR. The report also stated that the soil with concentrations exceeding the soil component of the groundwater ingestion exposure route ROs would be excluded by excavation of soil. The excavation would include soil in the vicinity of boring B-12. For obtaining a NFR determination from IEPA, the report proposed preventing the use

1. SITE BACKGROUND

1-3

of site groundwater for consumptive purposes in accordance with the IEPA-approved City of Chicago groundwater use ordinance and MOU, as outlined in 35 IAC Part 742.1015.

Additionally, the exposure pathway for soils exceeding ingestion ROs in the areas of the site, identified in the 1997 NFR letter, will be closed by the use of a soil management zone and engineered barriers. The construction worker ingestion exceedances in these areas will be remedied by providing notification to site workers should any future excavation and construction activities occur in these areas.

1.3 Path Forward The City of Chicago is submitting this RAP for the site, which outlines the containment and removal actions, the specific contaminants of concern, the physical area to be addressed, the confirmation sampling plan and the schedule of activities with estimated dates of completion through the recording of the NFR Letter. An SMZ describing the steps that will be taken to manage the excavated soils and ensure compliance with the requirements of solid waste regulations established in 35 IAC Part 807 for SMZs has been included per IEPA’s request.

2-1

SECTION 2

Remedial Action Plan

Soil with concentrations exceeding the Tier 1 and calculated Tier 2 and Tier 3 TACO ROs for the industrial/commercial ingestion and construction worker ingestion exposure pathways will be excavated during the construction of the Bensenville Ditch and managed during the development of the former Prologis remediation site for O’Hare International Airport use. This RAP addresses management and disposition of the impacted excavated soil. Note that based on agreement with IEPA, the groundwater monitoring requirements of 35 IAC Part 807 for this remedial action are waived and not addressed in the RAP because the groundwater ingestion exposure pathway will be eliminated by using the City of Chicago IEPA-approved groundwater ordinance and MOU.

It was originally planned that soil with lead concentrations exceeding the soil component of the groundwater ingestion exposure route ROs in the vicinity of Boring B-12 would be excluded by excavation of soil. Because of the depth of this soil, the ability to excavate it was limited. A Tier 3 evaluation was conducted to show that the lead-contaminated soil will not migrate above the TACO Class I groundwater standard at the property boundary. No offsite migration of site-specific constituents of concern (COC) has been modeled or directly measured in groundwater above Tier 2 TACO Class I groundwater remediation objectives (GRO). Groundwater use will be prohibited in accordance with the City of Chicago IEPA-approved groundwater ordinance and MOU. With the exception of implementing this groundwater ordinance and MOU, no further action is required for the groundwater ingestion exposure route.

2.1 Statement of Remedial Objectives ROs presented in the IEPA-approved February 2011 ROR are shown in Table 1. Industrial/commercial ingestion ROs are exceeded in the soil boring locations shown in Figure 4. The approved remedy in 1997 was to cover this contaminated soil with three feet of clean fill, three feet of surface water or a concrete building foundation or asphalt parking lot. Upon completion of the airport, these former barriers will be removed to develop the southern runway and the relocated Bensenville Ditch. The purpose of the RAP is to describe the remedial action that will be utilized to eliminate the soil ingestion and inhalation exposure pathways by creation of an SMZ and placement of new engineered barriers.

TABLE 1 Soil Remediation Objectives with a Comparison to the Highest Measured Soil Concentrations

COC Industrial/ Commercial

Construction Worker

Tier 2 RO Soil

Migration to Class I

Groundwater

Highest Measured Soil Concentration

Measured Exceedance

of Tier 2 SRO

Ingestion Inhalation Ingestion Inhalation

Methylene Chloride 760 24 12,000 34 2,400 a 0.18 (B-5, 2-3 feet below ground surface [bgs])

None

REMEDIAL ACTION PLAN

2-2

TABLE 1 Soil Remediation Objectives with a Comparison to the Highest Measured Soil Concentrations

COC Industrial/ Commercial

Construction Worker

Tier 2 RO Soil

Migration to Class I

Groundwater

Highest Measured Soil Concentration

Measured Exceedance

of Tier 2 SRO

Ingestion Inhalation Ingestion Inhalation

2- Methylnaphthalene

8,200 NRO 820 NRO 17.6 a 2.4 None

Naphthalene 41,000 270 4,100 10a 12 2.4 (B-4, 2-3 feet bgs)

None

Dieldrin 0.4 2.2 7.8 3.1 36.4 a 0.0052 (B-4, 2-3 feet bgs)

None

Lead 800 NRO 700 NRO 0.045 SPLP a 940 (B-12, 4-6 feet bgs), 0.58 SPLP

B-12 I/C, CW ingestion, soil migration to groundwater

Manganese 41,000 91,000 4,100 8,700 0.90 SPLP a 11,000 (B-12, 1-3 feet bgs), 1.6 SPLP

B-12 CW inhalation and ingestion, soil migration to groundwater

a Tier 2 value

Notes: NRO = no remediation objective, All values in milligram per kilogram (mg/kg), except for Synthetic Precipitation Leaching Procedure (SPLP) values, which are in milligram per liter (mg/L).

2.2 Proposed Remedial Action Approach Construction of the Bensenville Ditch requires excavation of the upper five to 10 feet of soils. Some of these soils exceed the industrial/commercial ingestion and soil migration to groundwater ROs, as determined in the 1997 investigation. This excavated soil will be placed in one of two SMZs located to the north and south of the ditch that is contiguous with the soils exceeding industrial/commercial ROs on the southern one-third of the site (see Figure 4). The new location of this consolidated soil will meet the requirements of an SMZ, as described in the solid waste regulations in 35 IAC Part 807. Based on the findings of the previous investigations, excavation of the upper five to 10 feet of soil in the new Bensenville Ditch area of the site (see Figure 4) may not completely remove the soil that exceeds the ROs, and closure of the ingestion exposure pathway will still be required.

Remedial options considered to address remaining impacted soil include excavation, engineered barrier installation, in situ chemical oxidation, bioventing, and enhanced aerobic bioremediation. Because of the shallow and limited nature of the soil exceeding ROs, the use of the site as an airport and the expedited nature of this remedial action, placement of engineered barriers is proposed as an effective remedy consistent with the site use. The remaining locations with soil exceeding the industrial/commercial ingestion ROs, and the proposed SMZs, will all be covered with a minimum of three feet of geologic material that

3. REMEDIAL ACTION PLAN

2-3

meets TACO residential ROs, or an approved impermeable geomembrane and a minimum of one foot of clean soil.

In accordance with the correspondence received from IEPA on November 30, 2011, clean fill from property under contiguous ownership at O’Hare International Airport that meets industrial/commercial ROs may be imported into the remediation site boundary. This is provided that samples of the soil fill have been analyzed for all 35 IAC Part 740 Target Compound List compounds at a rate of at least one sample every 2,500 cubic yards. Additionally, soils not meeting residential ROs are not to be commingled with soil that meets residential ROs. Based on all soil sample results to date, the current location of soils meeting residential ROs and soils meeting industrial/commercial ROs is indicated in Figure 4.

Soil from property under contiguous ownership at O’Hare meeting residential or industrial/commercial remediation objectives will be placed within like areas within the remediation site. Installation of a final three feet of clean fill meeting residential remediation objectives, or the approved geomembrane and one foot of clean soil, followed by planting native grasses to maintain the soil cover would comprise the active portion of the remedy where soil exceeds industrial/commercial ingestion remediation objectives (Figure 4). In addition, an industrial/commercial land use restriction and a construction worker safety program with notifications for invasive activities in select areas would be implemented. This plan is further described in the following sections.

2.2.1 Engineered Barrier Installation The proposed remediation area, where soil concentrations are above industrial/commercial or construction worker ingestion ROs is shown in Figure 4. Contaminated soil in this area will be covered with Bentomat CLT and one foot of clean fill, or three feet of clean fill. The Bensenville Ditch will be lined with either 3 feet of clean fill or a membrane liner overlain with one foot of compacted clay, and a sufficient quantity of rip rap to stabilize the remedy, to close the exposure pathway. The details of the final remedy, including construction of the engineered barrier in the ditch area, will be described in the Remedial Action Completion Report (RACR).

A geosynthetic clay liner (GCL) is a type of geocomposite that is frequently used in environmental containment applications. The CETCO GCLs consist of two layers of geotextiles surrounding a layer of low permeability sodium bentonite that are needlepunched together to increase shear resistance.

Bentomat CLT is a reinforced geosynthetic clay liner (GCL) consisting of a layer of VOLCLAY sodium bentonite between two geotextiles and laminated to a textured HDPE geomembrane. The addition of the geomembrane to the GCL increases the hydraulic resistance (the hydraulic conductivity of this material is less than 5 X 10-10 cm/sec), and the textured surface increases the interface friction between the GCL and adjacent substrate. These characteristics make this GCL ideal for more demanding landfill covers and liquid containment applications involving steep slopes. The Bentomat CLT technical specifications are listed in Appendix B.

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2-4

2.2.2 Proposed Soil Management Zones The purpose of the SMZs is to allow consideration and approval of onsite solutions to site soil contamination without violating the solid waste disposal regulations presented in 35 IAC Part 807 or 811 - 815. The uses of an SMZ at this remediation site will allow management of contaminated soils, placement of structural clean fill, and consolidation of contaminated soils within the remediation site.

In accordance with 35 IAC Part 740.535, this site qualifies for an SMZ for the following reasons:

All contaminants of concern within the remediation site have been identified by a CSI;

The horizontal and vertical dimensions and uses of the SMZs have been defined;

The SMZ satisfies the requirements of 35 IAC Part 742.305(a) through (f); and

All applicable requirements of 35 IAC Part 742 will be satisfied within the SMZ (e.g., all exposure routes will be addressed; institutional controls and engineered barriers will be in full compliance with 35 IAC Part 742, Subparts J and K).

The SMZs will be located outside of the site area meeting the residential land use ROs. Because of the construction schedule, most of the soil exceeding industrial/commercial ROs, as indicated in the 1991 through 1996 and 2010 investigations, that is excavated for the construction of the Bensenville Ditch will be consolidated in the SMZ located to the south of the ditch. The northern SMZ will be utilized, if needed, to consolidate any soil exceeding industrial/commercial ROs once the pond has been dewatered. The location and dimensions of the SMZs are shown in Figure 4.

2.2.3 Additional Closure Requirements To protect human health, it is proposed that the remedial action will include provisions to:

Restrict the property use to industrial/commercial.

Use the City of Chicago IEPA-approved groundwater ordinance and MOU to prohibit the use of site groundwater for potable purposes.

Require regular inspection and maintenance of the engineered barrier that will be placed in the area indicated on Figure 4.

Require construction worker notification for intrusive construction work. The areas containing soil where construction worker notification is required for intrusive activity are indicated on Figure 4.

2.2.4 Schedule The proposed schedule for RAP implementation and completion reporting with assumptions is as follows:

Schedule Activity

May 2013 Initiate area engineered barrier placement

July 2013 Complete engineered barrier placement

3. REMEDIAL ACTION PLAN

2-5

90 days from completion of confirmation sampling, barrier placement and site restoration

Submit draft RACR documenting completion of the remedial action

60 to 120 days from submittal of final RACR (timeframe depends on IEPA backlog)

Obtain comprehensive NFR from IEPA

3-1

SECTION 3

Conclusions

All soil with concentrations exceeding the site-specific industrial/commercial ROs will remain in place, or be consolidated into one of two SMZs, located in the area of the former pond or to the south of the relocated Bensenville Ditch. These SMZs are located in portions of the site that contained soils that exceeded industrial/commercial ROs. The contaminated soil that remains in place or is consolidated into the SMZ will be covered with at least three feet of clean fill, as defined by 35 IAC Part 742.1105, or with an approved barrier and one foot of compacted clay to close the industrial/commercial ingestion pathway.

Based on the confirmation sample and stockpile sample results following soil excavation and consolidation in the SMZs and construction of the engineered barrier, soil migration to groundwater Tier 2 or Tier 3 calculations will be used, if necessary, to document that no contaminants of concern in the SMZs are anticipated to migrate outside of the remediation site boundaries. These calculations will be provided in the RACR along with construction details of the SMZ and engineered barrier.

Other actions proposed for site closure include:

Restrict the property use to industrial/commercial.

Use the IEPA-approved City of Chicago groundwater ordinance and MOU to prohibit the use of site groundwater for potable purposes.

Require regular inspection and maintenance of the engineered barrier that will be placed in the area indicated in Figure 4.

Require construction worker notification for intrusive construction work. The areas containing soil where construction worker notification is required for intrusive activity are indicated in Figure 4.

4-1

SECTION 4

References

BPC Airport Partners. 2011. Comprehensive Site Investigation Report/Remediation Objectives Report. February.

CH2M HILL. 2010. Site Investigation Work Plan. August 10.

Environmental Design International. 2009. Phase I Environmental Site Assessment Report. December.

Environmental Resources Management. Site Investigation and Remedial Objectives Report, Nelsen Steel & Wire Co., Inc. Bensenville, IL. May 1997.

Illinois Environmental Protection Agency. No Further Remediation Letter. October 31, 1997.

Warzyn, Inc. 1991. Phase I Environmental Site Assessment. February.

Figures

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RICHARD M. DALEY

MAYORCITY OF CHICAGO

O’ HARE INTERNATIONAL AIRPORTBPC Airport Partners

Master Civil Engineer

PRIMERA, CH2M HILL, AND DB STERLIN

BOWMAN, BARRETT & ASSOCIATES,

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MAYORCITY OF CHICAGO

O’ HARE INTERNATIONAL AIRPORTBPC Airport Partners

Master Civil Engineer

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CONSTRUCTION WORKER NOTIFICATION AREA1997 NFR ENGINEERED BARRIER/

Appendix A

City of Chicago Groundwater Use Ordinance and Memorandum of Understanding

Appendix B

Tier 3 Analysis for Lead

Tier 3 Evaluation of Lead in Groundwater

A Tier 3 evaluation of the fate and transport of lead was conducted to evaluate whether the observed concentrations that exceed the Tiered Approach to Corrective Action Objectives (TACO) Tier 1 and Tier 2 concentrations in groundwater will be protective of potential future groundwater users at the nearest downgradient property boundary. The fate and transport of metals is affected by many physical and chemical parameters of the chemical and the groundwater-bearing matrix. The recommended analytical model used in TACO Tier 2 assessments (Equation R26) accounts for several of these parameters, including hydraulic conductivity, gradient, dispersion, and source concentration and dimensions. The R26 equation allows for decay in concentration, but it does not account for adsorption reactions that can act to attenuate trace metals in groundwater. Lead is widely known to possess a strong affinity for adsorption to mineral surfaces, and this affinity was incorporated into this Tier 3 analysis to better reflect actual site conditions.

The analytical model chosen for this Tier 3 evaluation is a modification of Equation R26 to allow for retardation via adsorption. Adsorption tendency may be described by the soil-water partition coefficient, Kd, which is the ratio of concentration adsorbed to soil (mg/kg) to the concentration in surrounding groundwater (mg/L), thus deriving units of L/kg. For lead, the reported range of Kd for unconsolidated materials in published literature is 5 to 100,000 L/kg (Allison and Allison, 2005; Sheppard and Thibault, 1990; Spitz and Moreno, 1996). Although the median and average lead Kd values are typically above 1,000 L/kg, the lowest reported value of 5 L/kg was used in this Tier 3 evaluation in the interest of being conservative.

It is also noted that TACO allows the use of pH-based substitution values for Kd or Ks (soil-water sorption coefficient) to assist in the determination of the retardation of metals (such as lead) via adsorption. The TACO Table J Kd values for lead range from 15 L/kg for a pH as low as 4.9 to 1,900 L/kg for a pH as high as 9.0. The pH of soils at the site range from 7.4 to 10.9, and water pH ranges from 6.93 to 11.1. The above evaluation shows that we have consulted available literature, the TACO regulations, and evaluated site-specific conditions to select the most conservative value of 5 L/kg (Allison and Allison, 2005; Sheppard and Thibault, 1990; Spitz and Moreno, 1996) for use in this Tier 3 evaluation.

The partition coefficient Kd is used to calculate a retardation coefficient, Rf, which decreases the effects of dispersion and groundwater velocity. The relationship Rf = 1 + bKd was used, where b is the dry bulk density of the aquifer matrix. The bulk density was assigned a typical value of 1.7 kg/L for clayey soil, corresponding to a particle density of 2.65 kg/L and a total porosity of 0.36. In this relationship, the dry bulk density, b = s(1-n)/n, where s is the particle density and n is the total porosity. All combined, the Rf used for lead in this Tier 3 calculation was 24.6 (the parameter is unitless).

The risk-based corrective action equation used for Tier 2 analyses (R26) in accordance with TACO was as follows:

SAN/PROLOGIS_RAP_DRAFT_REV_7_KD3.DOCX 5

In order to replace the first term of this R26 equation for the purpose of incorporating adsorption reactions (which reduces to 1.0 when the decay constant is set to zero), the following term was used (Domenico and Schwartz, 1998):

12

/ 2 ∝

Where: 

vx = average linear groundwater velocity in the direction of groundwater flow (Ki/n) t = time x = dispersivity in the direction of groundwater flow n = total porosity K = hydraulic conductivity i = hydraulic gradient This term of the equation represents the classic Ogata-Banks (1961) equation for transport in porous media, with Rf added to account for adsorption. The result of this substitution represents a three-dimensional model of transport with adsorption in groundwater (Domenico and Schwartz, 1998: equations 18.6 and 18.19). Because this Tier 3 equation has a time parameter and the R26 is designed for steady-state conditions, the two equations were compared to verify the applicability of the Tier 3 equation for longer time frames which would represent a steady-state condition. In order to verify the applicability of the Tier 3 equation, the Rf term was set to zero and the time was adjusted to achieve the same downgradient concentration at the property boundary as the R26 equation (0.0075 mg/L). The derived matching time was 3,000 years, so the Tier 3 model was considered verified for steady-state applicability at that time duration. Based on the above analysis, the Tier 3 model was then fixed using a 3,000-year time frame and the lead Rf was applied. The resulting concentration calculated at the site boundary (275 feet downgradient from the source) was 6.7 x 10-8 mg/L, over five orders of magnitude below the TACO Class I groundwater standard of 7.5 x 10-3 mg/L. The parameter values assigned in the Tier 3 model are listed in Table 1. Conclusion This Tier 3 evaluation demonstrates the relatively immobile nature of lead in groundwater due to adsorption processes, and confirms that lead concentrations in soil and groundwater under site-specific conditions are not expected to desorb, solubilize, and migrate above the TACO Class I groundwater standard at the property boundary.  

References Cited Allison, J.D. and T.L. Allison. 2005. Partition Coefficients for Metals in Surface Water, Soil, and Waste. U.S. EPA Document EPA/600/R-05/074.

Domenico, P.A. and F.W. Schwartz. 1998. Physical and Chemical Hydrogeology, 2nd ed. New York: Wiley. 506 pp.

Ogata, A. and R.B. Banks. 1961. A solution of the differential equation of longitudinal dispersion in porous media. U.S. Geol. Surv. Prof. Paper 411-A.

Sheppard, M.I. and D.H. Thibault. 1990. Default soil solid/liquid partition coefficients, Kds, for four major soil types: a compendium. Health Physics 59(4): 471-482.

Spitz, K. and J. Moreno. 1996. A Practical Guide to Groundwater and Solute Transport Modeling. New York: Wiley & Sons. 461 pp.

4.1.1 TABLE 1 Travel Distance Including Both Retardation and Dispersion Attenuation Mechanisms

Variable  Definition Units Notes

 Pb 

Csource concentration of lead in the source zone mg/L Site specific 5.80E‐01 

C(x) concentration of lead at distance x downgradient of source

mg/L Site specific 6.70E-08

x distance downgradient of source m Site specific 8.38E+01 

Sd source depth, perpendicular to groundwater flow in the vertical plane

m Site specific 2.00E+00 

αx longitudinal groundwater dispersivity m Site specific 8.38E+00 

αy transverse groundwater dispersivity m Site specific 2.79E+00 

αz vertical groundwater dispersivity m Site specific 4.19E‐01 

vw groundwater seepage velocity m/d Calculated, vw = Ki/θT 2.90E‐04 

K aquifer hydraulic conductivity m/d Site specific 3.26E‐02 

i hydraulic gradient unitless Site specific 3.20E‐03 

R COC retardation factor unitless R = 1+Kdρb/θT 2.46E+01 

Kd soil-water partition coefficient cm3/g Chemical specific Kd for metals

5.01E+00 

b soil bulk density g/cm3 TACO 1.70E+00 

n total porosity unitless TACO 3.60E‐01 

Sw source width, perpendicular to groundwater flow in the horizontal plane

m Site specific 6.71E+01 

Appendix C

Bentomat CLT Technical Specifications

L i n i n g T ec h n o Lo g i e s

www.CETCO.com 2870 Forbs Avenue Hoffman Estates, IL 60192 847.851.1800 | 800.527.9948

IMPORTANT: The information contained herein supersedes all previous printed versions, and is believed to be accurate and reliable. For the most up-to-date information, please visit www.CETCO.com. CETCO accepts no responsibility for the results obtained throught application of this product. CETCO reserves the right to update information without notice.

© 2007 ceTco | PrinTed in The UsA on recycLed PAPer

LAST UPDATED MAY 2007

TECHniCal REFEREnCE 401-BMClT

mATeriAL ProPerTy TesT meThod TesT FreqUency reqUired VALUes

Bentonite swell index1 AsTm d 5890 1 per 50 tonnes 24 mL/2g min.

Bentonite Fluid Loss1 AsTm d 5891 1 per 50 tonnes 18 mL max.

Bentonite mass/Area2 AsTm d 5993 40,000 ft2 (4,000 m2) 0.75 lb/ft2 (3.6 kg/m2) min.

gcL Tensile strength3 AsTm d 6768 200,000 ft2 (20,000 m2) 45 lbs/in (70 n/cm) mArV

gcL Peel strength3 AsTm d 6496 40,000 ft2 (4,000 m2) 3.5 lbs/in (6.1 n/cm) min.

gcL index Flux4 AsTm d 5887 Periodic 1 X 10-9 m3/m2/sec max.

gcL hydraulic conductivity4 AsTm d 5887 Periodic 5 X 10-10 cm/sec max.

gcL hydrated internal shear strength5

AsTm d 5321AsTm d 6243 Periodic 500 psf (24 kPa) typical

Bentomat CLT is a reinforced GCL consisting of a layer of sodium bentonite between two geotextiles, which are needlepunched together and laminated to a 20-mil (0.5mm) textured HDPE geomembrane.

Notes

1 Bentonite property tests performed at a bentonite processing facility before shipment to ceTco’s gcL production facilities.2 Bentonite mass/area reported at 0 percent moisture content.3 All tensile strength testing is performed in the machine direction using AsTm d 6768. All peel strength testing is performed using ASTMD6496.Uponrequest,tensileandpeelresultscanbereportedpermodifiedASTMD4632using4inchgrips.4 ASTMD5887Indexfluxandhydraulicconductivitytestingwithdeaireddistilled/deionizedwaterat80psi(551kPa)cellpressure,77 psi (531 kPa) headwater pressure and 75 psi (517 kPa) tailwater pressure. reported value is equivalent to 92 gal/acre/day. This fluxvalueisequivalenttoapermeabilityof5x10-10 cm/sec for typical gcL thickness. AsTm d 5887 testing is performed only on a periodic basis because the membrane is essentially impermeable.5 Peakvaluemeasuredat200psf(10kPa)normalstressforaspecimenhydratedfor48hours.Site-specificmaterials,GCLproducts, and test conditions must be used to verify internal and interface strength of the proposed design.

CERTiFiED PROPERTiESBEnTOMaT® ClT

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