REMOVAL ASSESSMENT REPORT FOR LANE PLATING WORKS

REMOVAL ASSESSMENT REPORT

FOR

LANE PLATING WORKS INCORPORATED

5322 BONNIE VIEW ROAD

DALLAS, DALLAS COUNTY, TEXAS

Prepared for

U.S. Environmental Protection Agency Region 6

Will Lombard, Project Officer

1445 Ross Avenue

Dallas, Texas 75202

Contract No. EP-W-06-042

Technical Direction Document No. 5/WESTON-042-16-004

WESTON Work Order No. 20406.012.005.0992.01

NRC No. N/A

CERCLIS ID TXN000607031

FPN No. N/A

EPA OSC William Rhotenberry

START-3 PTL Jose L. Ojeda

Prepared by

Weston Solutions, Inc.

Cecilia H. Shappee, P.E., Program Manager

5599 San Felipe, Suite 700

Houston, Texas 77056

(713) 985-6600

July 2016

Removal Assessment Report for Lane Plating Works Inc., Dallas, Dallas County, Texas

TDD No. 5/WESTON-042-16-004

Lane Plating Works Removal Assessment Report.doc i CERCLIS No. TXN000607031

EXECUTIVE SUMMARY

On 10 March 2016, the U.S. Environmental Protection Agency (EPA) tasked Weston Solutions,

Inc. (WESTON®), the EPA Region 6 Superfund Technical Assessment Response Team

(START-3) contractor, to perform a Removal Assessment (RA) at the Lane Plating Works, Inc.

site located in Dallas, Dallas County, Texas (Technical Direction Document [TDD] No.

5/WESTON-042-16-004). The RA was initiated in response to a request by the Texas

Commission on Environmental Quality (TCEQ) to EPA Region 6 stating enforcement actions

had been exhausted following an Agreed Order Follow-Up (Agreed Order Docket No. 2011-

0662-IHW-E) and Compliance Evaluation Investigation (CEI) conducted 21 October 2014.

START-3 RA activities were completed between 05 April 2016 and 13 April 2016 and included

performing air monitoring and compiling photographic documentation of containers within the

plating facility; compiling logbook and photographic documentation of on-site RA activities; and

collecting soil and liquid waste samples for analytical testing.

Soil sampling around the facility footprint was conducted 12 April 2016 through 13 April 2016

extending to a depth of approximately 3 inches below ground surface (bgs), while liquid waste

sampling was conducted 13 April 2016. A total of 36 soil samples and 4 liquid waste samples

were collected to determine the nature and extent of site-related, hazardous constituents

associated with electroplating waste (plating waste) in on-site soils, and to verify if liquids,

contained in an unknown number of drums and totes, were considered hazardous substances.

Soil and liquid samples were shipped to TestAmerica Laboratories in Houston, Texas, for

analysis. Soil samples were submitted for analysis of Metals and Hexavalent Chromium [Cr

(VI)]. Liquid waste samples were submitted for analysis of Metals, Hexavalent Chromium [Cr

(VI)], Corrosivity (pH), and Sulfide and Cyanide Reactivity. Soil analytical data was compared

to the EPA Regional Screening Levels (RSLs), Industrial Soil (THQ = 1.0), May 2016. The

liquid waste characterization results were compared to 40 CFR Part 261.

Based on the analytical results, hexavalent chromium, lead, and mercury contaminated soil was

present around the footprint of the building. Hexavalent chromium was reported in 17 grids

exceeding the EPA RSL of 6.3 mg/Kg. Hexavalent chromium contaminated soil ranged in

concentration from 167 mg/Kg (Grid E7) to 5,620 mg/Kg (Grid G7). Lead exceeded the EPA



Lane Plating Works Removal Assessment Report.doc ii CERCLIS No. TXN000607031

RSL of 800 mg/Kg in six grids. Mercury was observed above instrument detection limits in

several grids but only exceeded in one grid above the EPA RSL of 46 mg/Kg.

Four liquid waste samples were collected from two on-site totes and one tank labeled as a “rinse

water tank” and analyzed to confirm the presence of hazardous substances. Based on the

laboratory results, the liquid waste by definition is hazardous due to the characteristic of

corrosivity with a pH less than 2. Concentrations ranged from 0.6 to 2.15. Total chromium

present in the liquid samples ranged from 105,000 mg/Kg to 296,000 mg/Kg.

START-3 conducted air monitoring for acid gas, mercury vapors, and volatile organic

compounds (VOCs) during the preliminary site visit and throughout the soil and liquid waste

sampling activities. No readings above instrument detection levels were reported.

START-3 has prepared this Removal Assessment Report to describe the technical scope of work

that was completed as part of the TDD No. 5/WESTON-042-16-004 under Contract No. EP-W-

06-042 for EPA Region 6. The EPA On-Scene Coordinator (OSC) was William Rhotenberry.

The START-3 Project Team Lead (PTL) was José L. Ojeda.

The EPA Task Monitor did not provide final approval of this report prior to the

completion date of the work assignment. Therefore, Weston Solutions, Inc. has

submitted this report absent the Task Monitor’s approval.

The EPA Task Monitor has provided final approval of this report. Therefore,

Weston Solutions, Inc. has submitted this report with the Task Monitor’s approval.

X



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TABLE OF CONTENTS

Section Page

EXECUTIVE SUMMARY ................................................................................................. ES-I

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

1.1 PROJECT OBJECTIVES ...................................................................................... 1-1

1.2 SCOPE OF WORK ................................................................................................ 1-2

1.3 REPORT FORMAT .............................................................................................. 1-2

2 SITE BACKGROUND .................................................................................................. 2-1

2.1 SITE LOCATION ................................................................................................. 2-1

2.2 SITE DESCRIPTION ............................................................................................ 2-1

2.3 POTENTIAL SOURCES OF HAZAROUS MATERIALS .................................... 2-1

2.4 OPERATIONAL AND REGULATORY HISTORY ............................................. 2-2

2.5 SUMMARY OF PREVIOUS INVESTIGATIONS ................................................ 2-2

3 ACTIONS TAKEN ........................................................................................................ 3-1

3.1 SOIL SAMPLING ................................................................................................. 3-1

3.2 LIQUID WASTE SAMPLING .............................................................................. 3-2

4 ANALYTICAL METHODOLOGY .............................................................................. 4-1

4.1 SOIL SAMPLE ANALYSES ................................................................................ 4-1

4.2 LIQUID WASTE SAMPLE ANALYSES.............................................................. 4-1

4.3 DATA VALIDATION ........................................................................................... 4-2

5 SUMMARY OF ANALYTICAL RESULTS ................................................................ 5-1

5.1 SOIL SAMPLES RESULTS .................................................................................. 5-1

5.2 LIQUID WASTE SAMPLE RESULTS ................................................................. 5-2

5.3 AIR MONITORING RESULTS ............................................................................ 5-2



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LIST OF APPENDICES

Appendix A Removal Assessment Quality Assurance Sampling Plan (QASP)

Appendix B Digital Photographs

Appendix C Site Logbook

Appendix D Analytical Data Packages

Appendix E Data Validation Reports

Appendix F Technical Direction Document No. 5/WESTON-042-16-004



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LIST OF FIGURES

Figure 1-1 Site Location Map

Figure 2-1 Site Area Map

Figure 2-2 Site Property Map

Figure 3-1 Soil Sample Location Map

Figure 4-1 Soil Sample Exceedance Map

Figure 4-2 Soil Sample Results Map - Hexavalent Chromium

Figure 4-3 Soil Sample Results Map - Lead

Figure 4-4 Soil Sample Results Map - Mercury

LIST OF TABLES

Table 5-1 Summary of Soil Analytical Results

Table 5-2 Summary of Liquid Waste Analytical Results



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1 INTRODUCTION

Weston Solutions, Inc. (WESTON®), the EPA Region 6 Superfund Technical Assessment and

Response Team (START-3) contractor, was tasked by the U.S. Environmental Protection

Agency (EPA) Region 6 Emergency Management Branch (EMB) under Contract Number EP-

W-06-042 and Technical Direction Document (TDD) No. 5/WESTON-042-16-004 (Appendix F)

to conduct a Removal Assessment (RA) at the Lane Plating Works, Inc. site located in Dallas,

Dallas County, Texas. This RA was initiated in response to a request by the Texas Commission

on Environmental Quality (TCEQ) to EPA Region 6 stating enforcement actions had been

exhausted following an Agreed Order Follow-Up (Agreed Order Docket No. 2011-0662-IHW-E)

and Compliance Evaluation Investigation (CEI) conducted 21 October 2014. A Site Location

Map is provided as Figure 1-1. All figures and tables are provided as separate portable

document format (PDF) files. START-3 has prepared this report to describe the technical scope

of work that was performed during the RA at the Lane Plating Works, Inc. site.

1.1 PROJECT OBJECTIVES

START-3 provided technical support to EPA for performance of the Lane Plating Works, Inc.

site RA activities. The objectives of the RA were:

To determine the nature and extent of potentially hazardous substances associated with

electroplating waste (plating waste) in on-site soils.

To verify if liquids contained in an unknown number of totes and rinse water tanks

located within the facility contain hazardous substances.

The objectives of the RA were achieved by evaluating data obtained during the field

investigation through the collection of soil samples and liquid waste samples and reviewing

available background information including the TCEQ CEI reports. START-3 activities

included establishing a 50-foot by 50-foot grid system around the facility footprint. Five-point

composite surface soil samples were collected at a depth of 3 inches below ground surface (bgs)

within each grid. Liquid waste samples were collected from totes and rinse water tanks within

the facility for hazard characterization.




1.2 SCOPE OF WORK

The RA scope of work included the following activities:

Develop a site-specific Quality Assurance Sampling Plan (QASP) and health and safety

plan (HASP)

Conduct air monitoring inside the facility for acid gas, mercury vapors, and volatile

organic compounds (VOCs)

Establish a 50-foot by 50-foot grid around the facility footprint and collect five-point

composite soil samples.

Collect liquid waste samples from totes and rinse water tanks within the facility.

Review analytical soil sample data results and compare those analytical results to EPA

Regional Screening Levels (RSLs), Industrial Soil (THQ = 1.0), May 2016.

Review analytical waste sample data results and determine if the liquid contains

hazardous substances.

Samples were collected and analyzed in accordance with the START-3 QASP. A copy of the

QASP is located in Appendix A. Digital photographs of RA activities are included in Appendix

B.

1.3 REPORT FORMAT

This report has been organized as follows:

Section 1 - Introduction

Section 2 - Site Background

Section 3 - Actions Taken

Section 4 - Analytical Methodology

Section 5 – Summary of Analytical Results




2 SITE BACKGROUND

Information regarding site location, site description, and potential sources of hazardous material,

operational and regulatory history, and summary of previous investigations is presented in the

following subsections.

2.1 SITE LOCATION

The site is located at 5322 Bonnie View Road in Dallas, Dallas County, Texas, within a mixed

commercial and residential area. The approximate center of the site is located at Latitude

32.6878557° North and Longitude 96.7692897° West. The site encompasses approximately

4.655 acres according to the Dallas County Central Appraisal District. A relative of the owner

resides in a home located adjacent to, on the north side of the site; a residential area is located

0.25-mile northwest; to the east approximately 7 miles is H. Grady Spruce High School; and 0.3

miles to the south is Five Mile Creek that discharges into the Trinity River. A barbed-wire fence

and locked chain-link fence surrounds the property, and the building is locked with the windows

boarded up. There is no access to the site except by key at the locked gate. Site topography and

surface water drainage appears to slope to the south-southeast. A Site Area Map is provided as

Figure 1-2. A Site Property Map is provided as Figure 2-2.

2.2 SITE DESCRIPTION

Lane Plating Works, Inc. is an abandoned electroplating facility that contains an unknown

number of drums and totes, containing electroplating wastes from operations that ended in 2015.

Lane Plating Works, Inc. is currently controlled by Stag Management, Inc., a court-appointed

trustee. Typical electroplating process waste includes acids, bases, flammables, oxidizers,

cyanides, chromium-contaminated solids (sludge) and liquids, and Resource Conservation

Recover Act (RCRA) non-hazardous solids and liquids. The number and condition of the drums

and totes containing the electroplating wastes are not known at this time.

2.3 POTENTIAL SOURCES OF HAZAROUS MATERIALS

Information concerning the known or potential hazardous waste source areas at the site and the

constituents thought to be associated with each source are discussed in this subsection.




Based on the TCEQ investigation conducted on 04 November 2015 and on TCEQ sampling

activities on 19 November 2015, former site activities that contributed to potential sources

include the following:

Stripping metal parts of dirt, oil, grease, and scale in acid.

Grinding and buffing metal parts smooth prior to and during plating.

Pretreatment of metal parts using sodium hydroxide and sulfuric acid.

Copper plating using copper cyanide.

Zinc plating aluminum using nitric acid and zinc cyanide.

Nickel plating using nickel sulfate.

Chrome plating using chromic acid.

Electroplating wastewater treatment that included a surface impoundment.

Generation and storage of solid waste.

2.4 OPERATIONAL AND REGULATORY HISTORY

Lane Plating Works, Inc. has been in operation for over 50 years at the property as an

electroplating facility, conducting primarily (60-70%) hard chromium plating and cadmium

plating. Processes performed at the facility included chromate dips, chromic acid anodizing,

hard chrome plating, cadmium plating, black oxide coating, electroless nickel plating,

passivation, machining, and grinding. In addition to electroplating, the facility also operated a

lead melting pot used to repair anodes used in the plating baths. The facility housed two chrome

tanks, and according to TCEQ Air Compliance Section reports, the emission from the tanks was

controlled by a mesh-pad scrubber and mist eliminator fume hood system. The last updated

Notice of Registration (NOR), dated 18 January 2011, listed 10 hazardous wastes and 3 Class II

Industrial Solid Wastes.

2.5 SUMMARY OF PREVIOUS INVESTIGATIONS

Information regarding previous on-site investigations conducted by state regulatory agencies are

summarized in this section.

In February 2010, the TCEQ Dallas/Fort Worth (Region 4) office conducted an unannounced

investigation at the facility. Sixteen 55-gallon drums of hazardous plating waste were observed




unlabeled and missing necessary identification and accumulation dates. A Notice of Violation

(NOV) letter was transmitted to the facility on 24 February 2010 for alleged violations of 30

Texas Administrative Code (TAC) 35.69 for failure to properly label hazardous waste containers.

On 19 January 2011, the TCEQ DFW office conducted an Industrial and Hazardous Waste

(IHW) CEI at the facility. Based on observations made during the CEI, it was determined that

soil sampling was necessary. As a result of the CEI, five alleged violations and one additional

issue regarding the rules for IHW were documented and formal enforcement action was initiated.

A proposed Agreed Order was issued to the facility on 5 July 2011. This Agreed Order directed

the facility to complete technical requirements, including immediately ceasing any additional

unauthorized discharges; removing all discharged industrial solid waste, visibly impacted soils,

and waste containers from the facility; properly disposing of waste at an authorized facility;

developing and implementing procedures to ensure that all containers storing hazardous waste

were removed within the allotted accumulation time limit and transported to a facility authorized

to accept the waste; submitting annual waste summaries for calendar years 2008 and 2009; begin

maintaining all records of all hazardous and industrial solid waste activities; and submitting an

Affected Property Assessment Report (APAR).

On 16 September 2014, the TCEQ Enforcement Division requested the TCEQ Region 4 office to

conduct an on-site investigation at Lane Plating Works, Inc. to determine if the facility had

complied with the Agreed Order.




3 ACTIONS TAKEN

On 23 March 2016, EPA, TCEQ, and START-3 conducted a preliminary reconnaissance to

observe current site conditions and discuss project objectives for the RA. START-3 conducted

air monitoring within the building for acid gas, VOCs, and mercury vapors during the site visit.

During the preliminary reconnaissance, soil and liquid waste sampling strategies were discussed

between EPA and START-3 and included a systematic method for determining nature and extent

of hazardous constituents in on-site soils and verifying potentially hazardous liquids contained in

an unknown number of totes and drums within the facility.

Following the preliminary reconnaissance, EPA and START-3 developed a sampling strategy

that included establishing a 50-foot by 50-foot sampling grid surrounding the footprint of the

facility. On 05 April 2016, START-3 mobilized to the site and established 43, 50-foot by 50-

foot grids around the exterior facility utilizing a Trimble Pro-XRT Global Positioning System

(GPS) unit. The corner points of each grid were marked with pin flags and labeled. A Soil

Sample Location Map is provided as Figure 3-1.

START-3 conducted soil and liquid waste sampling activities from 12 through 13 April 2016.

All sampling activities were completed in accordance with the START-3 QASP. Any deviations

to the QASP was discussed with the EPA OSC and noted in the field logbook. Site logbook

notes are included in Appendix C. Sample nomenclature reflected the grid location, date, sample

matrix, sample depth, and sample type (field sample vs. duplicate sample). Detailed soil and

liquid waste sampling information is included in the following subsections.

3.1 SOIL SAMPLING

START-3 conducted soil sampling to determine the nature and extent of hazardous substances

associated with electroplating waste (plating waste) in on-site soils. During sampling activities,

30 composite surface soil samples (29 normal samples and 1 field duplicate sample) were

collected from 0 to 3-inches bgs using dedicated plastic scoops. The grids sampled included the

following:




A1 A7 B7 C7 D7 F7 H1 H5

A2 B1 C1 D1 E1 G1 H2

A3 B2 C2 D2 E7 G5 H3

A6 B6 C6 D6 F1 G7 H4

A total of five grab samples plus one field duplicate was collected using dedicated plastic scoops

from grids LPW01-E6, LPW01-E6 (duplicate), LPW02-F7, LPW03-D5, LPW04-E2, and

LPW05-G3 at the direction of the EPA OSC.

Composite soil samples were homogenized in a dedicated disposable plastic bag and

immediately transferred into a pre-cleaned 4-ounce glass jar with a Teflon-lined lid. Grab soil

samples were collected and immediately placed in pre-cleaned 4-ounce glass jar with a Teflon-

lined lid. All soil samples collected were stored in a cooler with ice.

3.2 LIQUID WASTE SAMPLING

On 13 April 2016, START-3 collected four liquid waste samples (three normal samples and one

duplicate sample) from two on-site totes and one tank labeled as a “rinse water tank”. The

samples were collected to determine if the liquid contained hazardous substances. Sample IDs

assigned to the liquid waste samples includes: LPW01-AQ, LPW02-AQ, LPW02 (duplicate)

and LPW03-AQ. The liquid samples were collected using dedicated Coliwassa samplers to

collect representative samples of liquid waste. Liquid samples collected using the Coliwassa

sampler were immediately transferred into pre-cleaned glass containers with a Teflon-lined lid.

The liquid waste samples were stored in a cooler on ice and separate from the soil samples to

maintain sample integrity.




4 ANALYTICAL METHODOLOGY

TestAmerica Laboratories in Houston, Texas conducted sample analyses, and data validation

was performed by the EPA Team as part of the TDD requirements. These tasks were conducted

in accordance with the WESTON Quality Assurance Program, and the EPA Team QASP

prepared under TDD No. 5/WESTON-042-16-004.

A standard data management system that includes using bound field logbook, site photographs,

sample management and tracking procedures, document control, and inventory procedures for

the laboratory data was utilized. SCRIBE software was utilized to manage and track sample

information for samples submitted to the participating laboratories.

Information regarding laboratory analyses and data validation is presented in the following

subsections.

4.1 SOIL SAMPLE ANALYSES

START-3 submitted a total of 36 soil samples for the following parameters:

TAL Metals by Method 6010B

Mercury by Method 7471A

Hexavalent Chromium [Cr(VI)] by Method SW‐846 7196A

4.2 LIQUID WASTE SAMPLE ANALYSES

Four liquid waste samples collected as part of this investigation were analyzed for the following

parameters:

TAL Metals by Method 6010B

Mercury by Method 7471A

Hexavalent Chromium [Cr(VI)] by Method SW‐846 7196A

Corrosivity (pH) Reactivity by Method 9045C

Cyanide (Reactivity) by Method 9012

Sulfide (Reactivity) by Method 9034.

TestAmerica Laboratories reported the analytical results in data packages meeting EPA Team




requirements for importing and managing in SCRIBE. The laboratory documentation in these

data packages includes records of instrument readings, calculations, calibrations, and quality

assurance checks.

Appendix D includes the analytical data packages submitted by TestAmerica Laboratories.

4.3 DATA VALIDATION

The EPA Team performed data review and validation in accordance with EPA National

Functional Guidelines for Inorganic Superfund Data Review, August 2014. The data packages

were reviewed to verify they met the technical requirements and Quality Assurance (QA)

guidelines established for the respective analytical methods. The following list includes the items

evaluated for each laboratory sample delivery group (as applicable):

The completeness of the laboratory reports, verifying that all required components of the

reports were present and that the samples indicated on the accompanying chain-of-

custodies were addressed in the reports.

The sample receipt temperature was reviewed to verify the cooler temperature was

within acceptable range.

Holding times were reviewed to verify the samples were extracted and/or analyzed

within the required holding time.

The case narrative was reviewed for any noted sample receipt, sample preservation,

and/or analytical exceptions (instrument performance checks, initial calibration, initial

and continuing calibration verification checks, etc.).

Laboratory blanks were reviewed to determine whether laboratory contamination was

present.

Internal standards were reviewed to verify the recoveries were within the acceptable

range.

Laboratory control samples and/or laboratory control sample duplicates were reviewed

to verify the accuracy of the method.

Matrix spike/matrix spike duplicate samples were reviewed to determine whether matrix

interference was present and to determine if laboratory precision was within the

acceptable range.

Serial dilution samples were reviewed to verify that the percent difference was within

the acceptance criteria.

Field duplicates were reviewed to verify that field precision was within the acceptable

range.




Reporting limits (Method Detection Limit [MDL], Limit of Determination [LOD], and

Limit of Quantitation [LOQ]) were reviewed to confirm they were adjusted to reflect

dilution factors, where applicable.

Sample results were reviewed to confirm that the detected concentration was within the

instrument calibration range. If the concentration exceeded the instrument calibration

range, the data were reviewed to determine if the sample was reanalyzed at a secondary

dilution.

The EPA Team reviewed the analytical results to verify that the data were acceptable for their

intended use in meeting the objectives of the project. The analytical results for the samples

collected for this project are acceptable for use with qualifiers assigned during validation. Data

validation reports are included in Appendix E.



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5 SUMMARY OF ANALYTICAL RESULTS

Soil and liquid waste sample analytical information is presented in the following subsections.

5.1 SOIL SAMPLES RESULTS

During field assessment activities, a total of 36 soil samples (30 composite samples and six grab

samples) including duplicate samples were collected and analyzed to determine nature and extent

of hazardous substances in soil. A review of the soil analytical results indicates that two

prevalent hazardous substances, hexavalent chromium and lead, were detected at levels

exceeding EPA RSLs criteria (Industrial Soil [THQ = 1.0], May 2016). Mercury was detected in

several soil samples above instrument detection limits but only Grid C2 exceeded the EPA RSL

criteria. A summary of soil analytical results is included in Table 5-1. Figure 4-1 illustrates

sample grids that exceeded for either hexavalent chromium, lead, and/or mercury. Individual

exceedance grid maps for hexavalent chromium, lead, and mercury have been prepared as

Figures 4-2 through 4-4.

A total of 30 composite soil samples (29 normal samples and 1 duplicate) were collected from a

grid system established around the footprint of the facility. Hexavalent chromium was detected

in 17 grids above the EPA RLS of 6.3 mg/Kg (Figure 4-2). Hexavalent chromium ranged in

concentration from non-detect 2.24 U (Grid A1) to 5,620 mg/Kg (Grid G7). The lowest detected

levels of hexavalent chromium was reported at a concentration of 167 mg/Kg (Grid E7).

As shown in Figure 4-3, lead was detected in five composite soil samples above the EPA RSL of

800 mg/Kg in Grids C2 (1,250 mg/Kg), D6 (1,810 mg/Kg), E7 (1,470 mg/Kg), F7 (5,400

mg/Kg), G5 (1,950 mg/Kg), and G7 (4,660 mg/kg). Lead concentrations raged from 28.9 mg/Kg

to as high as 5,400 mg/Kg (F7).

Mercury was detected at low levels in a number of girds across the site but only one grid (C2 –

113 mg/kg) exceeded the EPA RSL of 46 mg/Kg (Figure 4-4).

Four grab soil samples plus one field duplicate sample were collected from grids E6, F7, D5, E2,

and G3 to determine concentrations of hazardous constituents in soil at locations immediately

adjacent to the facility building. The IDs assigned to the grab soil samples included: LPW01-E6,



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LPW01-E6 (duplicate), LPW02-F7, LPW03-D5, LPW04-E2, and LPW05-G3. Hexavalent

chromium was non-detect (2.72 U mg/Kg) at Grid E2 (Sample ID: LPW04-E2), a sample point

immediately located along the north side of the facility. Grab sample LPW03-D5 (Grid D5) was

taken from the southern side of the facility and reported hexavalent chromium at a concentration

of 54.5 mg/Kg above the EPA RSL of 6.3 mg/Kg. Along the east side of the building, one grab

sample was collected (ID LPW05-G3) in Grid G3 and reported hexavalent chromium at a

concentration of 267 mg/Kg. LPW01-E6, collected from Grid E6, reported hexavalent

chromium at a concentration of 2,130 mg/Kg. Sample LPW02-F7 (Grid F7) reported hexavalent

chromium at a concentration of 130 mg/Kg.

5.2 LIQUID WASTE SAMPLE RESULTS

During field activities on 13 April 2016, four liquid waste samples (including three normal

samples and one duplicate sample) were collected to confirm the presence of hazardous

substances. A summary of liquid waste sample results is included in Table 5-2. The four liquid

waste samples are hazardous waste based on the characteristic of corrosivity with pH less than 2

according to SW-846 Method 9040C. LPW01 and LPW02 reported pH at 0.85 and 0.6,

respectively. LPW03 reported pH at 2.15. Total chromium ranged from 105,000 mg/Kg

(LPW01) to 296,000 mg/Kg (LPW02).

5.3 AIR MONITORING RESULTS

START-3 conducted air monitoring for acid gas, mercury vapors, and VOCs during the

preliminary site visit and throughout the soil and liquid waste sampling activities. No readings

above instrument detection levels were reported.

Documents

REMOVAL ASSESSMENT REPORT FOR LANE PLATING WORKS