response action plan - rice creek commons · 3.0 irp site k response action plan 3.1 general the...

Response Action Plan

IRP Site K Former Twin Cities Army

Ammunition Plant (TCAAP) Arden Hills, Minnesota

Prepared for:

RAMSEY COUNTY 2015 North Van Dyke Street

Maplewood, Minnesota 55109-3796

Prepared by:

WENCK ASSOCIATES, INC. 1802 Wooddale Drive

Suite 100 Woodbury, Minnesota 55125-2937

(651) 294-4580

Wenck File #0979-03April 24, 2014

Table of Contents

1.0 INTRODUCTION .................................................................................................................... 1-1

2.0 SITE DESCRIPTION AND BACKGROUND .................................................................................. 2-1

3.0 IRP SITE K RESPONSE ACTION PLAN ....................................................................................... 3-1

3.1 General ............................................................................................................................. 3-1 3.2 Chemicals of Concern and Risk-Screening Criteria .......................................................... 3-1 3.3 Proposed Response Actions – IRP Site K .......................................................................... 3-2

3.3.1 Site Preparation Activities ................................................................................ 3-2 3.3.2 Soil Removal Actions ........................................................................................ 3-3 3.3.3 Soil Removal Actions and Verification of Response Action Effectiveness ....... 3-4 3.3.4 Venting System Installation .............................................................................. 3-4 3.3.5 Venting System Effectiveness Monitoring ....................................................... 3-4 3.3.6 Site Security ...................................................................................................... 3-5

3.4 Proposed Response Actions – Hot Spots ......................................................................... 3-6 3.4.1 Excavation Activities ......................................................................................... 3-6 3.4.2 Soil Removal Actions and Verification of Response Action Effectiveness ....... 3-6

4.0 RESPONSE ACTION IMPLEMENTATION REPORTING ............................................................... 4-1

5.0 REFERENCES ......................................................................................................................... 5-1

TABLE Table 1 Summary of Hot Spots in Plexus Section 1013 FIGURES Figure 1 Site Location Map Figure 2 Proposed VOC Verification Sampling Locations Figure 3 CRA Soil Investigation Map Figure 4 Proposed Excavation Map Figure 5 Hot Spot Locations Figure 6 Soil Stockpile Venting Concept Plan APPENDICES Appendix A Rotron Blower Specification Sheet

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1.0 Introduction

This document presents a soil Response Action Plan (RAP) developed in accordance with Minnesota Pollution Control Agency (MPCA) Voluntary Investigation and Cleanup (VIC) Program for impacted areas within Plexus Section 1013 (including Installation Restoration Program [IRP] Site K) at the former Twin Cities Army Ammunition Plant (TCAAP) located within the Southeast ¼ of the Southwest ¼ of Section 9 Township 30 North, Range 23 West of the 5th Principal Meridian, (the Site). The general Site boundaries are identified in Figure 1. This RAP has been prepared to provide sufficient detail to allow the implementation of Response Actions (RAs) addressing:

1) Soils in the unsaturated zone (i.e., above the water table) affected by chlorinated solvents and located beneath former Building 103 at levels in excess of the MPCA Tier I Residential Soil Reference Values (SRVs) and / or Screening Soil Leaching Values (SLVs) and

2) Hot spot soil areas affected by other Contaminants of Concern (COCs) including arsenic, copper, iron and polychlorinated biphenyls (PCBs).

A Site Construction Contingency Plan (CCP) has previously been submitted for review under a separate cover. The MPCA approved the CCP subject to several comments in a letter dated May 31, 2013. Wenck addressed the MPCA comments and submitted a response to the MPCA for consideration on June 7, 2013. In the event that hazardous materials, including but not limited to asbestos-containing waste, lead paint, munitions or explosives of concern (MEC), nuclear, biological or chemical contamination (NBC), or previously unidentified releases of hazardous substances or petroleum, are encountered at the Site during project activities, the incident notice and other provisions of the CCP will be implemented. Also, in accordance with the approved CCP, the location of utility service entry points, floor drains, trench drains, dry wells, sumps and other structures of interest have been identified in anticipation of the removal of the building slab and implementation of this RAP. The proposed locations of forty-two verification sampling locations are depicted on Figure 2. While not every slab penetration is proposed to be sampled, the most significant features (pits and sumps) will generally be sampled, as well as a representative number of locations across the foundation footprint. The County has contracted with Carl Bolander & Sons Co. (Bolander) to complete all Site demolition and response action activities at the Site. Bolander has subcontracted with Wenck Associates, Inc. (Wenck) to provide environmental engineering services to support the project. Bolander will complete the Site clearance activities to satisfy the Army’s obligation to remediate soil in the Leased Property to Tier II Industrial SRVs, additional remediation required under Bolander’s contract with the County to remediate all Site soil to MPCA Tier I Residential SRVs, and perform environmental response actions to obtain a Commissioner’s Certificate of Completion for Site soil. As part of this process, the County, with assistance from Wenck, will seek removal of the Site from the state and federal Superfund lists and modification of the environmental covenant and existing land use restrictions to allow residential redevelopment throughout the Site.

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This RAP has been prepared for the exclusive use of Ramsey County, Bolander and Wenck, and other contractors and subcontractors working at their direction and having a specific, contractual relationship with Ramsey County, Bolander or Wenck.


2.0 Site Description and Background

The Site is located within in the SE ¼ of the SW ¼ of Section 9, Township 30 North, Range 23 West of the 5th Principal Meridian. The area of the Site is approximately 21 acres in size. The Site location is shown in Figure 1. Building 103 was a 417,122 square foot manufacturing building. It was originally used for 50 caliber ammunition manufacture and decommissioned after World War II. The building was used for various munitions manufacture by Honeywell and then Alliant Techsystems from the 1960s through 1998. Some radioactive materials were handled in the building and those areas were decontaminated in compliance with NRC requirements. Trichloroethene contaminated groundwater was discovered to be infiltrating the storm sewers, and discharging to Rice Creek, at Site K in the 1980s. The sewers were grouted and a horizontal trench shallow groundwater remediation system installed on the west side of Building 103. The system has operated since 1986 for a trichloroethene plume, as part of the IRP cleanup of Site K. The progress of cleanup is documented in the annual performance report for TCAAP. The limits of the VOC plume in the perched groundwater have been defined to be generally beneath and immediately northwest of former Building 103. The remedy selected in the Operable Unit 2 (OU2) Record of Decision (ROD) consisted of seven components that incorporated the existing groundwater extraction trench and air stripper, which began operation in August 1986. The remedy also included additional investigation of the unsaturated soils beneath the building slab. OU2 Explanation of Significant Differences (ESD) #1 added land use controls as a remedy component in 2009. The building was wrecked to grade in 2009. Alliant Techsystems conducted a soil excavation in 2009 of solvent impacted soil on the east portion of the building slab near a sump that was suspected to be the source of the groundwater contamination. Alliant placed potassium permanganate in the excavation in an effort to remediate residual groundwater contamination in the VOC source area. Monitoring of this remedial action continues. Information related to the 2009 Conestoga Rovers Associates (CRA) soil remediation project is provided in Figure 2. Consultants working on behalf of Alliant Techsystems conducted some additional soil investigation activities that appear to indicate the potential presence of impacted soil located generally downgradient of the excavated VOC source area and upgradient of the remedial groundwater collection system. Boring locations GP-18 and GP-19 appear to indicate high concentrations of VOCs approximately halfway between the excavated sump area and the remedial groundwater capture system. Whether this is an independent source, or the artifact of Dense Non-Aqueous Phase Liquid (DNAPL) migration along preferential pathways of migration from the sump area has not been definitively established. Other contaminants including arsenic, copper, iron, PCBs and VOCs were also detected above the Tier 1 Residential Soil Reference Values (SRVs) and / or Screening Soil Leaching Values (SLVs) in subsurface soil samples in other areas of Plexus Section 1013.


3.0 IRP Site K Response Action Plan

3.1 GENERAL The main objective of the RAP is to provide a detailed design for the proposed RAs that will protect public health and the environment from releases or threat of releases of hazardous substances, pollutants, or contaminants associated with:

the chlorinated solvent impacted soils beneath the southern portion of the former building and one apparently isolated VOC hot spot, and non-VOC contamination hot spots

3.2 CHEMICALS OF CONCERN AND RISK-SCREENING CRITERIA RAs are warranted to address elevated levels of the following COCs in the subsurface based on the results of the previous investigations at the Site:

Volatile Organic Compounds (VOCs) Metals (arsenic, copper and iron) Polychlorinated Biphenyls (PCBs)

The soil contaminants listed above will be remediated to comply with MPCA Tier I residential SRVs and Screening SLVs (as appropriate) in place at the time the Response Action Plan Implementation Report is submitted to the MPCA and EPA. A list of the specific COCs currently identified on the Site at concentrations exceeding these criteria is provided below:

Parameter1

Tier I Residential SRV (mg/kg)

[June 2009] Screening SLV (mg/kg)

[May 2013] Acetone 340 8.4

Methylene Chloride 97 0.017 Cis-1,2-Dichloroethene 8 0.21

Trichloroethene 29 0.029 Arsenic 9 ---1

Copper 100 ---1

Iron 25,0002 ---1

PCBs 1.2 0.13

1 Historical metals soils data were not compared to Screening SLVs as metals have been assessed in

groundwater throughout the Site and have not been identified as a groundwater issue. Also, MPCA has indicated that they do not think it is appropriate to apply metals SLVs to a site unless a significant, known release of metals has occurred. Therefore, evaluation of soil to groundwater was not considered warranted for metals.


2 The value shown for iron is not an SRV. The iron value was chosen as a site-specific cleanup standard after

consultation with and approval by the MPCA as documented in their Technical Assistance Letter dated January 27, 2014.

3.3 PROPOSED RESPONSE ACTIONS – IRP SITE K The proposed and presumptive remedy for Site K is excavation followed by ex-situ stockpile venting. Upon successful remediation, the stockpiled material will be placed back in the area from which it was excavated. Wenck will observe the soil excavation and stockpiling procedures to ensure proper documentation and adequate protection of human health and the environment. Wenck will be responsible for ensuring compliance with the approved RAP, and the CCP, and will dictate field decision-making, such as the need to stop work and evaluate risks. The work will be conducted under the existing Site-specific Site Health and Safety Plan (SHSP). Any other unknown wastes or sources of contamination uncovered during the implementation of this RA will be assessed and mitigated per the requirements of the MPCA-approved Site CCP. 3.3.1 Site Preparation Activities Excavation and material handling activities will be conducted by Bolander and will involve the use of appropriately trained personnel (i.e., in accordance with 40 CFR 1910.120) operating backhoes and managing field operations. All workers will be required to submit 40-hour Hazardous Waste Site Operations (HAZWOPER) certificates and the most recent annual 8-hour refresher certificate prior to conducting any work on-site. Copies of all HAZWOPER certificates will be kept on-Site. Prior to initiating any soil removal actions, existing groundwater monitoring wells BH9 (01U609) and BH11 (01U611) will be properly sealed. The wells will be sealed by a Minnesota Department of Health licensed well driller. These wells will be replaced after the excavation area is restored to grade, presumably in June 2015. After the wells are sealed the project area will be demarcated with a combination of wood lath and construction fencing. Figure 3 includes a map showing the proposed excavation limits. The excavation area is estimated to be approximately 29,000 ft2. However, the final area will be determined through soil confirmation sampling. Soil sampling procedures are discussed in Section 3.3.3 of this report. After the project area is established the first task will be to remove the southern half of the former building slab. The concrete rubble generated during the slab removal activities will be crushed and recycled as Class VI construction aggregate. Should stained concrete be identified during slab removal activities (i.e., oil-stained or chemically impacted concrete), it will be segregated for appropriate off-site disposal. After the southern portion of the former building slab is removed the slab remaining on the northern half of former Building 103 will be prepared for soil staging and treatment. An area approximately 175’ by 250’ will be used to stage and treat VOC impacted soil from beneath both Buildings 103 and 102 adjoining south-southwest. The soil staging area has been designed to accommodate approximately 11,400 cubic yards of VOC contaminated soil; approximately 8,500 cubic yards from beneath Building 103, and approximately 2,400 cubic yards from beneath Building 102, plus a contingency volume of 500 cubic yards. Excavation of VOC contaminated soil from beneath Building 102 is governed by a Building 102-specific RAP submitted to the MPCA under separate cover.

The approximate location of the soil staging area is shown on Figure 3. The perimeter of the stockpile area will be lined with three-foot tall free-standing concrete barriers. The northern half of the building


slab, used as the treatment area described above, will be removed following treatment of the impacted soil. Prior to removal of this portion of the slab it will be assessed in accordance with the approved CCP and the VOC verification sampling shown on Figure 2. 3.3.2 Soil Removal Actions Excavation activities will begin on the east end of the area shown on Figure 4 and move to the west and southwest. The excavation will proceed vertically to the shallow groundwater table. The groundwater table is located at a depth of approximately 7 feet below grade within the proposed excavation area. The estimated quantity of soil to be removed from the proposed excavation has been calculated to be approximately 8,500 cubic yards. This estimate includes a 15% contingency to account for 1) benching the sidewalls to a 1:1 slope for safety and 2) any unknown pockets of contamination not previously identified through past investigation. Prior to placing any excavated material in the stockpile staging area the material will be mechanically pulverized (i.e., tilled in-situ prior to placement in the venting pile) to ensure homogenization and the breaking up of clumped soil. This will allow for the maximum amount of surface area of soil particles to be affected by moving air during venting. Prior to placing any soil on the slab the staging area will be prepared. Preparatory activities will include the following:

The perimeter of the staging area will be lined with concrete barriers to hold the toe of the pile in place. All perforations and cracks in the concrete slab within the pile staging area will be sealed prior to placing soil. Plastic sheeting (60-mil thickness) will be placed at the toe of the pile extending approximately 3 feet in from the barrier and extend over the side and top of the pile (see Figure 4). All plastic sheeting used in covering the pile will overlap on the sides and ends a minimum of five feet. The plastic cover will be held in place using sand bags or tires.

After the soil has gone through the pulverization process and the staging area has been properly prepared, a two-foot layer of soil will be laid on the slab. After the two-foot lift of soil is laid down the horizontal vent piping will be laid as shown on Figure 4. The horizontal vent piping will consist of 4-inch diameter perforated drain-tile (minimum 20-slot or 0.02” perforations). Three piping runs are proposed to be installed in the pile each connected to a separate blower. Each piping run will be continuous with no joints. Each pipe run will be wrapped in a fabric sock to protect the slots from sediment intrusion. After each section of vent pipe is in place and plumbed an additional approximately three feet of impacted soil will be carefully laid in the staging area. After the three-foot lift of soil is laid down the fresh-air horizontal piping will be laid down as shown in Figure 4. The horizontal fresh air piping will be connected to numerous vertical pipes that will perforate the outer plastic liner and allow fresh air to enter the pile. The horizontal pipe will consist of 4-inch diameter perforated drain tile same as the vent pipe. The vertical pipe will consist of schedule 40 PVC pipe. The vertical pipe will be connected to the drain tile pipe with 90-degree dry-fit T-connectors. After the fresh air piping is in place an additional two feet of soil will be carefully placed on the pile. After all of the impacted soil is placed within the venting pile the entire pile will be enveloped in 10-mil plastic sheeting.


3.3.3 Soil Removal Actions and Verification of Response Action Effectiveness After the impacted soil has been removed from the excavation and placed in the stockpile staging area, discrete confirmatory soil samples will be collected from each sidewall and the excavation floor (only if the excavation floor is above the shallow groundwater table) to determine the efficacy of the removal action. Excavation sidewall sampling will occur at a rate of one sample per 45 lineal feet of sidewall. Floor confirmation sampling (if applicable) will be collected at a rate of one sample per 500 square feet of unsaturated floor space. Samples will be sent to the laboratory for chemical analysis. Laboratory method and procedures will follow the project QAPP (TCAAP Redevelopment #2 Site). Soil samples will be analyzed for VOCs by EPA Method 8260B. Discrete sampling will be conducted per Field SOP F-1 (Discrete Soil Sampling Procedures). A copy of Field SOP F-1 is included in Appendix C of the project QAPP. Each soil confirmation sample will be located using GPS technology. These activities will follow the procedures discussed in Field SOP F-5 (GPS Data Collection Procedures). A copy of Field SOP F-5 is included in Appendix C of the project QAPP. The soil results will be compared to the appropriate MPCA Tier I SRV and Screening SLV to determine whether or not additional excavation will be required. If the confirmation soil sample results are below their respective MPCA Tier I SRV and Screening SLV (where applied), then the excavation will be left open (side slopes will be no steeper than 1:1 for safety purposes) until the soil stockpile is successfully remediated. Upon receipt of laboratory results indicating that the soil pile has been remediated to below Action Levels the material will be placed back in the excavation and compacted in place. If the confirmation soil sample results are above their respective cleanup criteria then additional soil will be excavated and consequently additional confirmation sample(s) will be collected. This process will continue until all sidewall and floor samples are below their respective cleanup criteria. 3.3.4 Venting System Installation After all impacted soil is placed in the stockpile staging area the entire pile will be enveloped in plastic sheeting. The plastic sheeting facilitates two purposes; 1) keeping the pile from becoming saturated and 2) controlling the movement of air from the atmosphere through the pile and then out the effluent side of the blower system. After constructing the stockpile the vent piping will be connected to three separate blower systems. Each blower system will consist of a five horse power (hp), high volume/low vacuum Rotron™ blower system (cut sheet is included in Appendix A). Each blower will equipped with appropriate gauging, valving, electrical control panel, interlocks (as necessary) and air sample ports. In addition, each blower system will be also equipped with a steel moisture knock-out tank. The tank systems will be equipped with interlock switches, inline air filters, manual drain valves and pressure-relief devices. The blower system will be housed by either a large steel box or trailer. A 4-inch diameter by approximately 10 foot tall PVC stack will be added to vent the blower system effluent. 3.3.5 Venting System Effectiveness Monitoring To monitor the venting system’s overall effectiveness, effluent samples will be collected from the system at startup then every month thereafter. The samples collected during system operation will be used to determine 1) system effectiveness as well assist in estimating potential shutdown (i.e., mass removal becomes asymptotic). Samples will be collected from the blower effluent stacks for EPA Method TO-15 analysis. In addition, 12 one-inch diameter monitoring points will be installed in the stockpile to allow real-time vacuum monitoring during system operation. The monitoring vents will be constructed of flush-threaded PVC pipe and 10-slot screens. The screens will extend from approximately


six inches from the base of the pile to approximately one foot below the top of the pile. A small section of riser pipe will extend approximately one foot above the top of the pile. The riser pipe will be outfitted with a valved sample port for connection to vacuum gauge. Readings will be taken from the monitoring points on a monthly basis. Prior to system startup Wenck will perform an air assessment to determine whether an air permit will be required for system operation. If warranted, Wenck will obtain a permit prior to system startup. Should the assessment show a permit is not required for this application Wenck will provide the results in the Response Action Implementation report. During the period the stockpile treatment system is operational, Wenck will inspect the stockpile on weekly basis to ensure the integrity of the plastic stockpile cover. Rips or damage to the plastic cover will be repaired immediately by Wenck or Bolander staff. Post-treatment soil samples will be collected from the treated soil stockpile to ultimately determine achievement of cleanup goals. Hand auger soil samples will be collected from the pile to determine successful remediation. Wenck proposes to collect soil samples from 20 random locations from the pile for evaluation. This equates to approximately one sample per 1,700 square feet of stockpile. Three grab samples will be collected from each location. One sample from approximately one foot from the top of the pile, one sample from the center and approximately one foot from the base of the pile and submitted to Pace Analytical for VOCs by EPA Method 8260B. Laboratory methods and procedures will follow the project QAPP (TCAAP Redevelopment #2 Site). The soil results will be compared to the appropriate MPCA Tier I SRV and Screening SLV to determine whether or not additional remediation will be required. If the soil sample results are below their respective MPCA Tier I SRV and Screening SLV (where applied), then the soil pile will be returned to the original excavation. If the soil results are above their respective cleanup criteria then the venting activities will continue. This process will continue until all stockpile samples are below their respective cleanup criteria. If after twelve months of treatment the pile has not reached the cleanup goals discussed above the entire pile will be hauled to an approved landfill for disposal. Copies of all analytical data and disposal documentation will be provided in the Response Action Implementation report. 3.3.6 Site Security The entire 427-acre property is secured by fencing and a locking gate with a sign indicating “TCAAP Remediation Project.” During the period of time the excavation area is open, and the soil treatment system is operating, the area will be secured by a snow fence to restrict access to the area. Additionally, the area will be marked with signs, indicating “Superfund Cleanup in Process – Hazardous Substances Present – Unauthorized Personnel Stay Out.”


3.4 PROPOSED RESPONSE ACTIONS – HOT SPOTS 3.4.1 Excavation Activities Six hot spot locations (i.e., historical data exceeding the MPCA Tier 1 SRVs and / or Screening SLVs, where applied) are shown on Figures 4 and 5, and summarized in Table 1. These impacted areas will be mitigated through excavation and off-site disposal. Excavation and hauling activities will be conducted by Bolander and will involve the use of appropriately trained personnel (i.e., in accordance with 40 CFR 1910.120) operating backhoes and managing field operations. Each “hot spot” will be located using GPS technology and marked with a lath. These activities will follow the procedures discussed in Field SOP F-5 (GPS Data Collection Procedures). A copy of Field SOP F-5 is included in Appendix C of the project QAPP. Each “hot spot” will be secured prior to initiating excavation work. Work zones and “exclusion zones” will be established in cooperation with Bolander personnel prior to initiating field activities. In addition, the area requiring excavation will be marked using lath, ribbons and marking paint. The work will be conducted under the existing Site-specific Site Health and Safety Plan (SHSP). Any other unknown wastes / sources of contamination uncovered during the implementation of the “hot spot” response actions will be assessed and mitigated per the requirements of the Site CCP. Hot spot K08SB at the north end of the slab appears to be an isolated area of TCE impacts. This area will be excavated, as described above, but rather than hauling the excavated material off-site for disposal, the impacted media will be added to the ex-situ soil venting stockpile for on-site treatment. 3.4.2 Soil Removal Actions and Verification of Response Action Effectiveness Wenck will observe the soil excavation and loading procedures to ensure proper documentation and adequate protection of human health and the environment. Wenck will be responsible for ensuring compliance with the approved RAP / DRAP, and the CCP, and will dictate field decision-making, such as the need to stop work and evaluate risks. At present, there are a total of six “hot spots” that will be remediated under this RAP within Plexus Section 1013. The list of hot spots is summarized in Table 1 and shown on Figure 3. In general, the presumptive Response Action (RA) for mitigation of the “hot spots” will include the excavation of a predetermined area (approximately 10’ x 10’ by 6’ [i.e., 3 feet above and 3 feet below where the investigation sample was collected] which equates to approximately 20 cubic yards or 30 tons of soil). For “hot spots” where investigation samples were collected at the surface (i.e., less than 3 feet below ground surface), the excavation will extend 3 feet below the investigation sample depth. Excavated soils will be directly placed into covered, over-the-road trucks and hauled to the SKB Rosemount Industrial Waste Facility in Rosemount, Minnesota (permit #-SW-386) for disposal under an approved Special Waste Profile for Disposal. After the soil has been removed from the “hot spot” discrete confirmatory soil samples will be collected from each sidewall (total of four) and the excavation floor (one total) to determine the efficacy of the removal action. Samples will be sent to the laboratory for chemical analysis. Laboratory method and procedures will follow the project QAPP (TCAAP Redevelopment #2 Site). Soil samples will be analyzed for the parameters that define the individual “hot spot” (i.e., only the analytes exceeding regulatory risk-screening criteria). Discrete sampling will be conducted per Field SOP F-1 (Discrete Soil Sampling Procedures). A copy of Field SOP F-1 is included in Appendix C of the project QAPP.


The soil results will be compared to the appropriate MPCA Tier I SRV and Screening SLV to determine whether or not additional excavation will be required. If the confirmation soil sample results are below their respective MPCA Tier I SRV and Screening SLV (where applicable), then the excavation will be leveled to ensure safe side-slopes. If the confirmation soil results are above their respective cleanup criteria then additional soil will be removed from the “hot spot,” and additional confirmation sample(s) will be collected from areas that were further excavated. This process will continue until all sidewall and floor samples are below their respective cleanup criteria.


4.0 Response Action Implementation Reporting

Upon completion of the approved RAs, a RAP Implementation Report summarizing the remedial activities and analytical results will be submitted to the County, the MPCA, and the USEPA for review and comment. The Implementation Report will include, at a minimum, the following:

1. A general overview of Response Action implementation scope and goals, 2. Discussion of Response Action implementation activities and contingencies, 3. Conclusions and Recommendations for additional Response Actions (if needed), 4. Tabulated and summarized data, appropriate figures and any applicable disposal records, 5. Waste disposal records and scale tickets.


5.0 References

Conestoga-Rovers & Associates. Removal Action Work Plan, Site K. Twin Cities Army Ammunition Plant, Arden Hills, Minnesota. April 2009.

Plexus Scientific Corporation. Environmental Site Assessment for 774-acre Excess Parcel Phase I and

Phase II Report Final, Twin Cities Army Ammunition Plant, Arden Hills, Ramsey County, Minnesota, February 20, 2004.

Tecumseh/Wenck Installation Support Services. Addendum Report for Phase I and Phase II

Environmental Site Assessment, Twin City Army Ammunition Plant. May 2005. Tetra Tech. Supplemental Remedial Investigation Field Sampling Plan, Twin Cities Army Ammunition

Plant, 585-Acre Transfer Property, prepared for RRLD, LLC. September 11, 2008. Wenck Associates. Phase I Environmental Site Assessment: 427 acres of the New Brighton/Arden Hills Superfund Site (former Twin Cities Army Ammunition Plant), Sections 9 and 16, Township 30

North, Range 23 West Arden Hills, Minnesota. February 2012. Wenck Associates. Construction Contingency Plan, Former Twin Cities Army Ammunition Plant (TCAAP),

427-acre Transfer Property, Sections 9 and 16, Township 30 North, Range 23 West Arden Hills, Minnesota. May 2013.

Wenck Associates. Quality Assurance Project Plan, Former Twin Cities Army Ammunition Plant (TCAAP),

427-acre Transfer Property, Sections 9 and 16, Township 30 North, Range 23 West Arden Hills, Minnesota. October 2013.


Table 1Summary of Hot Spots in Plexus Section 1013

TCAAP Redevelopment Site #2Arden Hills Minnesota

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Sample Locations within the IRP Site K VOC Groundwater Plume

Sample ID Depth (Ft) Sampler Source IDSample Purpose Sample Date Analyte Category Analyte SRV SLV Value Units

6 CRA 13 Site K 2/1/1984 VOC Trichloroethene 29 0.029 0.13 mg/Kg10 CRA 13 Site K 2/1/1984 VOC Trichloroethene 29 0.029 0.13 mg/Kg10 CRA 13 Site K 2/1/1984 VOC Acetone 340 8 16 mg/Kg10 CRA 13 Site K 2/6/1984 VOC Trichloroethene 29 0.029 0.08 mg/Kg10 CRA 13 Site K 2/6/1984 VOC Methylene chloride 97 0.017 0.03 mg/Kg4 CRA 13 Site K 2/2/1984 VOC Methylene chloride 97 0.017 0.02 mg/Kg

10 CRA 13 Site K 2/2/1984 VOC Trichloroethene 29 0.029 31 mg/Kg10 CRA 13 Site K 2/2/1984 VOC trans-1,2-Dichloroethene 11 0.416 1.5 mg/Kg7 CRA 13 Site K 2/7/1984 VOC Trichloroethene 29 0.029 5.3 mg/Kg9 CRA 13 Site K 2/7/1984 VOC Trichloroethene 29 0.029 25 mg/Kg

Blue Snake-1 3 CRA 13 Site K 2/2/1984 VOC Acetone 340 8 13 mg/KgBlue Snake-2 2.5 CRA 13 Site K 2/2/1984 VOC Acetone 340 8 10 mg/KgGP-1 5.5 CRA 15 Site K 3/1/2000 VOC Trichloroethene 29 0.029 0.3 mg/kg

6.1 CRA 15 Site K 3/1/2000 VOC Trichloroethene 29 0.029 4.9 mg/kg6.1 CRA 15 Site K 3/1/2000 VOC Trichloroethene 29 0.029 2.9 mg/kg

GP-5 3 CRA 15 Site K 2/28/2000 VOC Trichloroethene 29 0.029 0.41 mg/kgGP-6 4 CRA 15 Site K 2/28/2000 VOC Trichloroethene 29 0.029 0.57 mg/kgGP-9 6 CRA 15 Site K 2/28/2000 VOC Trichloroethene 29 0.029 0.2 mg/kgGP-10 6 CRA 15 Site K 2/28/2000 VOC Trichloroethene 29 0.029 0.65 mg/kg

6.5 CRA 15 Site K 2/29/2000 VOC cis-1,2-Dichloroethene 8 0.208 0.52 mg/kg6.5 CRA 15 Site K 2/29/2000 VOC Trichloroethene 29 0.029 7.2 mg/kg5 CRA 15 Site K 2/29/2000 VOC cis-1,2-Dichloroethene 8 0.208 0.32 mg/kg5 CRA 15 Site K 2/29/2000 VOC Trichloroethene 29 0.029 1.5 mg/kg

11 CRA 15 Site K 3/1/2000 VOC Trichloroethene 29 0.029 140 mg/kg8.5 CRA 15 Site K 3/1/2000 VOC Trichloroethene 29 0.029 13 mg/kg8.5 CRA 15 Site K 3/1/2000 VOC Trichloroethene 29 0.029 0.99 mg/kg7 CRA 15 Site K 3/1/2000 VOC cis-1,2-Dichloroethene 8 0.208 0.36 mg/kg7 CRA 15 Site K 3/1/2000 VOC Trichloroethene 29 0.029 5.3 mg/kg

GP-20 3.5 CRA 15 Site K 3/1/2000 VOC Trichloroethene 29 0.029 6.1 mg/kgGP-21 6.7 CRA 15 Site K 3/1/2000 VOC Trichloroethene 29 0.029 0.38 mg/kgGP-22 6 CRA 15 Site K 3/1/2000 VOC Trichloroethene 29 0.029 0.62 mg/kgRI-1013-13-SS 6 Tetra Tech 21 ESA 06/25/2007 VOC Trichloroethene 29 0.029 0.495 mg/kg

6 Tetra Tech 21 ESA 06/26/2007 VOC cis-1,2-Dichloroethene 8 0.208 0.79 mg/kg6 Tetra Tech 21 ESA 06/26/2007 VOC Trichloroethene 29 0.029 5.15 mg/kg14 Tetra Tech 19 ESA 4/22/2008 VOC Trichloroethene 29 0.029 804 mg/kg6 Tetra Tech 21 ESA 06/26/2007 VOC Trichloroethene 29 0.029 0.953 mg/kg

14 Tetra Tech 21 ESA 06/26/2007 VOC cis-1,2-Dichloroethene 8 0.208 2.1 mg/kg6 CRA 13 Site K 2/2/1984 VOC Methylene chloride 97 0.017 0.02 mg/Kg8 CRA 13 Site K 2/2/1984 VOC Methylene chloride 97 0.017 0.03 mg/Kg

SLF 4 CRA 13 Site K 2/2/1984 VOC Trichloroethene 29 0.029 0.04 mg/KgOW2-83 8 CRA 12 Site K 7/20/1983 VOC Trichloroethene 29 0.029 70 mg/KgSDW-3 6 CRA 16 Site K 6/17/2009 VOC Trichloroethene 29 0.029 0.31 mg/kgB-2 6.5 CRA 16 Site K 6/18/2009 VOC Trichloroethene 29 0.029 0.14 mg/kgB-1 8 CRA 16 Site K 6/18/2009 VOC Trichloroethene 29 0.029 4.8 mg/kgHot Spot Sample Locations

Sample ID Depth (Ft) Sampler Source IDSample Purpose Sample Date Analyte Category Analyte SRV SLV Value Units

K02MW 0 CRA 14 Site K 7/14/1992 Inorganic Iron 25000 - 28000 mg/kgK07SB 0 CRA 14 Site K 7/14/1992 Inorganic Copper 100 - 344 mg/kgK08SB 6 CRA 14 Site K 7/13/1992 VOC Trichloroethene 29 0.029 13 mg/kg

6 Tetra Tech 19 ESA 4/9/2008 Inorganic Copper 100 - 200 mg/kg6 Tetra Tech 19 ESA 4/10/2008 Inorganic Iron 25000 - 78000 mg/kg0 CRA 12 Site K 7/19/1983 PCB Total PCBs 1.2 0.125 1.25 mg/Kg0 CRA 12 Site K 7/19/1983 Inorganic Copper 100 - 247.1 mg/Kg

RI-1013-16 6 Tetra Tech 19 ESA 4/19/2008 Inorganic Arsenic 9 - 9.8 mg/kgSLA-83* 0 CRA 12 Site K 7/19/1983 PCB Total PCBs 1.2 0.125 0.47 mg/KgSLB-83* 0 CRA 12 Site K 7/19/1983 PCB Total PCBs 1.2 0.125 0.59 mg/KgSS1013-02* 0 Plexus 17 ESA 1/11/2003 PCB Total PCBs 1.2 0.125 0.53 mg/kgSS1013-03* 0 Plexus 17 ESA 1/11/2003 PCB Total PCBs 1.2 0.125 0.39 mg/kgSS1013-05* 0 Plexus 17 ESA 1/11/2003 PCB Total PCBs 1.2 0.125 0.21 mg/kg

Notes: = Sample point corresponds with an existing well

* = Indicates a sample exhibiting a PCB concentration in excess of the Screening SLV but less than the Tier 1 Residential SRV. This historical data point is not considered a Hot Spot due to the fact that PCBs have not been identified in the groundwater during past investigation or has been included on the Contaminants of Concern (COC) list as it relates to Site K.

BH7

BH8

BH9

BH11

GP-2

RI-1013-18

BH10

SLC-83

RI-1013-06

GP-14

GP-15

GP-18

GP-19

RI-1013-14-SS

Engineers - ScientistsBusiness Professionalswww.wenck.com

Building 103

35

10

35

County Road I

Highway 96

Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX,Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS UserCommunity

RAMSEY COUNTY

Building 103 - Site Location Map

DEC 2013

Figure 11800 Pioneer Creek CenterMaple Plain, MN 55359-04291-800-472-2232

2,000 0 2,0001,000Feet

2012 Aerial Photograph (Source: ESRI)

WenckPath: L:\0979\02\mxd\Bldg 103\Site Location Map.mxdDate: 12/20/2013Time: 10:53:55 AM User: ShuJC0243

Operable Unit 2 of the New Brighton/Arden Hills Superfund Site (the samearea occupied by the Twin CitiesArmy Ammunition Plant in 1983,when the Site was placed on the NPL.)

Site K Boundary

http://www.wenck.com

Proposed VOC Sample Collection LocationsCCP Implementation

1013VOC-38

1013VOC-37

1013VOC-36

1013VOC-35

1013VOC-26

1013VOC-25

1013VOC-24

1013VOC-39

1013VOC-33

1013VOC-29

1013VOC-27

1013VOC-04

1013VOC-01 1013VOC-02

1013VOC-03

1013VOC-05

1013VOC-07

1013VOC-10

1013VOC-06

1013VOC-09

1013VOC-12

1013VOC-08

1013VOC-14

1013VOC-15

1013VOC-13

1013VOC-11

1013VOC-18

1013VOC-20

1013VOC-17

1013VOC-21

1013VOC-19

1013VOC-22 1013VOC-23

1013VOC-321013VOC-311013VOC-30

1013VOC-28

1013VOC-34

1013VOC-42

1013VOC-411013VOC-40

1013VOC-16

Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP,swisstopo, and the GIS User Community


1800 Pioneer Creek CenterMaple Plain, MN 55359-04291-800-472-2232

WenckRAMSEY COUNTY

Path: L:\0979\02\mxd\Bldg 103\Proposed VOC Sample Collection Locations with Test Pits.mxdDate: 4/23/2014 Time: 2:31:52 PM User: shujc0243

130 0 13065Feet ±

Figure 2


APR 2014

LegendESA Section 1013

! ! ! ! ! ! !

! ! ! ! ! ! !

! ! ! ! ! ! !

Excavated Area

!( Floor Drain

!( Pit

!( Sump

") Proposed VOC Sample Location


Note: This figure was taken from the CRA reportentitled "Removal Action Completion Report Site K,Twin Cities Army Ammunition Plant, Arden Hills,Minnesota" and dated August 2009

WenckFigure

Hot Spot Locations beyond Main Excavation Area

K02MWIron

K07SBCopper

RI-1013-06Iron

RI-1013-06Copper

RI-1013-06-SSIron

RI-1013-16Arsenic

RI-1013-06-SSCopper

RI-1013-16-SSArsenic

K08SBTrichloroethene

SLC-83Copper

Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP,swisstopo, and the GIS User Community


1800 Pioneer Creek CenterMaple Plain, MN 55359-04291-800-472-2232

WenckRAMSEY COUNTY

Path: L:\0979\02\mxd\Bldg 103\Investigation Detail Map.mxdDate: 4/25/2014 Time: 10:22:50 AM User: shujc0243

130 0 13065Feet ±

Figure 4


APR 2014

LegendESA Section 1013

ESAMask

Excavated Area

!( DRO Values over 100 mg/kg

!(Hot Spot Location (Sample result aboveMPCA Tier I SRV and/or Tier 1 SLV)


SS1013-02

SS1013-05

SS1013-03

SS1013-02Approximate location of a historical PCBsoil sample concentration that exceededthe MPCA's May 2013 Screening SLV but isless than Tier 1 Residential SRV

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175'-0"

250'-0"

Soil Staging Area(approx. 43,750 ft2)

Wenck Figure 5 Proposed

Excavation Map

Note: This figure was taken from the CRA reportentitled "Removal Action Completion Report Site K,Twin Cities Army Ammunition Plant, Arden Hills,Minnesota" and dated August 2009

HOT SPOT LOCATION

Revised 03-12-14

250'

175'

Revised 03-12-14

IRP SITE K / BUILDING 102BOLANDER /RAMSEY COUNTY

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