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Chemical Commodities, Inc., Removal Funded Action, 320 ecology and environment* inc. CLOVERLEAF BUILDING 3, 6405 METCALF, OVERLAND PARK, KANSAS 66202, TEL. 913/432-9961 International Specialists in the Environment MEMORANDUM TO: Paul Doherty, EPA/DPO FROM: Lynn Parman, E & E/TAT THRU: Joe Chandler, E & E/TATLr " - DATE: November 15, 1989 SUBJECT: Chemical Commodities Removal Funded Action ___ 320 South Blake St., Olathe, Kansas TDDtt: T07-8907-027B PANtt: TKS0010RFA Activity #: TIXL3 S00130106 SUPERFUND RECORDS TNTRODUCTION; On July 18, 1989, the Ecology and Environment, Inc., Technical Assistance Team (E & E/TAT) was tasked by the U.S. Environmental Protection Agency (EPA) Emergency Planning and Response (EP&R) group to assist with removal activities at Chemical Commodities, Inc., 320 South Blake St., Olathe, Kansas. E & E/TAT was to obtain a complete inventory of chemical products at the facility, collect samples of unknown materials, conduct field screening of the unknown products, and insure proper segregation of chemicals according to their hazardous characteristics. In addition, documentation of all site activities was to be recorded on a daily basis. BACKGROUND: Chemical Commodities, Inc., (CCI) is a company that operated as a chemical broker which has purchased and resold a variety of chemical products over the last several years. On December 6, 1988, a CCI truck caught tire while transporting over 3000 pounds of potentially explosive ammonium perchlorate to a CCI warehouse in Shawnee, Kansas. Several violations were cited in the incident, resulting in subsequent investigations of regional CCI facilities. A site assessment of the CCI warehouse in Olathe was conducted by E & E/TAT, December 20-27, 1988 (see site assessment, TDD#: T07-8812-015A), resulting in the discovery of several hazardous conditions. Many incompatible chemicals were being stored together, extensive product leakage was occurring from numerous containers, severe water damage of chemical containers was observed due to leaking roofs, and many poorly labeled or unlabeled chemicals were present throughout the site. Several shock/heat sensitive chemicals were also being stored in the warehouse, producing a potentially explosive condition. recycled paper Four groundvater monitoring wells were installed immediately around the perimeter of the facility by the Kansas Department of Health and Environment (KDHE). Analytical results of samples collected from these veils by KDHE personnel on January 6, 1989, indicated elevated levels of the following chlorinated solvents: Tetrachloroethene Trichloroethene Dichloroethene Tetrachloromethane Trichloroethylene Tetrachloroethylene In addition, a significant concentration of chlorinated solvents was detected in groundwater which vas previously sampled by KDHE from an on-site monitoring well installed by CCI. As a result of these findings, E & E/TAT was tasked by the EPA to precede with a detailed sampling plan, designed to further delineate the extent of soil and groundwater contamination originating from the site. Site activities were conducted February 10-24, 1989 (site assessment report, TDD#: T07-8902-02A), which resulted in the following confirmations and conclusions: * Elevated organic solvent levels exist in groundwater on-site and immediately off-site, with contaminant levels decreasing away from the site. * Elevated organic solvent levels exist in surface water on-site and immediately off-site, creating a significant potential for contaminated run-off from the site. * Significant concentrations of chlorobenzene and 2-butanone are present in surface soil near a bottle crusher. * Excessive levels of organic and chlorinated solvents are present in subsurface soil on-site and immediately off-si te. * Numerous unmarked and/or unlabeled containers are being stored which contain chemicals potentially hazardous to the environment and human health. Two additional monitoring wells were installed around the site perimeter EPA during this period. On May 24, 1989, E & E/TAT responded to a reported explosion at the CCI site in Olathe. The incident occurred as an employee was dismantling a 10,000 gallon storage tank with a cutting torch, igniting residual vapors within the tank. Although no injuries were reported, the resulting explosion expelled the top of the tank, leaving it suspended from one side. The compilation and nature of these events resulted in the initiation of an Action Memorandum to perform site cleanup at Chemical Commodities, Inc. Authorization vas given to the ERCS contractor (Riedel Environmental Services, Inc.) and E & E/TAT to begin activities pertaining to the removal funded action on July 19, 1989. The first phase of this project (tasked by this TDD) vould entail compiling an inventory of all chemical products on-site, conducting chemical screening of unknown and/or unlabeled materials to detect any hazardous characteristics, and segregation of chemicals by hazard class into proper storage facilities. SITE ACTIVITIES (July 19 - August 16, 1989); E & E/TAT arrived on-site July 19, 1989, where they were met by EPA/OSC George Hess, employees of Riedel Environmental Services, Inc., and representatives from the U.S. Coast Guard Atlantic Strike Force. An assessment vas conducted of the entire site, including air monitoring for organic vapors, explosive atmospheres, and oxygen deficient environments in the chemical storage areas. Radiation levels vere also measured throughout the site. No organic vapors above background vere detected in the breathing zone by an HNU, with the exception of 0.5 ppm in shed B. All areas of the site exhibited 0% LEL, 21.52 Q~, and no radiation levels above background were detected. As a result of a reported mercury spill in the main warehouse, the mercury vapor concentration was also measured -in this facility during the site inspection. A level of 0.003_mg/m was detected in the warehouse, well below the TLV-TWA of 0.05 mg/m . Alphabetical labels were assigned to each area of the site where chemicals were being stored, to aid in the organization of a work plan (see site map). The inventory process began north of the CCI business office, in sheds J, K, and L, as E & E/TAT labeled the chemical containers (crates, boxes, drums, bottles, etc.) with consecutive numbers specific to each shed (J-001, J-002..., K-001, K-002..., etc.). In addition, a documentation form was completed for each item, providing information on the chemical's quantity, container type and condition, manufacturer, hazardous properties, and chemical name, if available. This information was entered into a chemical database (see attached Inventory of Chemical Products). Chemical containers which were leaking or structurally unsound were overpacked or repackaged to prevent additional release to the environment, and to facilitate relocation of the materials. Unknown and/or unlabeled chemical products were sampled and analyzed by field screening techniques to determine any hazardous characteristics. Results of these tests were also included on the documentation forms. Shed D was initially utilized as an on-site laboratory for this purpose, although collected samples were later transported to the EPA lab, 25 Funston Rd., Kansas City, Missouri, for analysis by E & E/TAT personnel. In accordance with the site safety plan, all solid unknowns were collected in level C protection, and liquid unknowns were collected in level B protective gear. After analysis, the remaining sample material was returned to the site and stored in shed E. After the inventory and sampling in these three sheds was completed (July 28, 1989), all chemicals were temporarily relocated to other areas on-site, until space became available to designate storage areas for the various hazard classes. Sheds J, K, and L were then released to Jerald Gershon, president and owner of CCI, with the understanding that they were to be demolished, and disposed of in a sanitary landfill as solid waste. Mr. Gershon was also restricted from any further unauthorized removal of chemicals from the site while cleanup activities were being conducted. The contents of the remaining sheds and trailers on-site (A,B,C,E,F,G,H,I, and 0) were documented and sampled in a similar manner. Many of these sheds and trailers, which had been utilized by CCI for chemical storage, were without any type of lighting, contained evidence of water damage, and were not adequately secured. Numerous corroded, broken, and leaking containers were discovered in the facilities which required repackaging or overpacking. Once this task was completed (August 15, 1989), materials began to be moved into structures which were designated to serve as storage areas for the various hazard classes of chemicals. The matter of assigning the chemicals to hazard classes was performed by Steve Dunaway, ERCS/Chemist. A material was considered to be a "regulated" product if it fell under FIFRA, TSCA, RCRA, CVA, or FDA control. In addition, if the total chemical volume exceeded the reportable quantity by CERCLA guidelines, it was also classified as a regulated material. The ERCS team was instructed to weigh all containers of regulated chemicals (unless total weight was known) before being moved to their respective areas, to determine the exact quantity of material present. The storage areas for these materials, along with their corresponding hazard classes, are as follows: Shed or Trailer Hazard Class C-A (south room of C) Acids C-B (north room of C) Caustics E ORM-A, ORM-B, ORM-E F Flammables & Combustibles G Reactives H Poisons, ORM-A, ORM-B, ORM-E I Oxidizers 0 Regulated Drugs, Oxidizers Organic peroxides and other potentially explosive materials were temporarily stored in a room adjacent to area S, inside the main warehouse. The majority of these items were subsequently transported to a nearby quarry for detonation. Explosives which were manufactured for military use were removed from the site by U.S. Army representatives from Fort Riley, Kansas. The remaining potentially explosive materials were detonated on site. (Jnlabeled items, and chemicals of unknown hazard class, were temporarily placed in two areas of the site until additional information could be obtained from the manufacturers, or until sample analysis results vere received.
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