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CERCLA 120(h) Notice Covenant, Access Provisions and Deed Restrictions
For the
Bannister Transformation & Development LLC Deed
The following CERCLA Covenant and Access Provisions along with the Other Deed Provisions will be
placed in the Bannister Transformation & Development LLC Deed for the property referenced in this
FOSET to ensure protection of human health and the environment and to preclude any interference
with ongoing or completed remediation activities.
I. CERCLA NOTICE, COVENANTS AND ACCESS PROVISIONS: In accordance with Section 120(h)(3) OF
THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT OF
1980 (42 U.S.C. § 9620(h)(3)): For the property, the Grantor provides the following notice,
description, and covenants and retains the following access rights:
A. Notices Pursuant to Section 120(h)(3)(A)(i)(I) and (II) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (42 U.S.C. § 9620(h)(3)(A)(i)(I) and (II)):
Pursuant to section 120(h)(3)(A)(i)(I) and (II) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (42 U.S.C. § 9620(h)(3)(A)(i)(I) and (II)), available
information regarding the type, quantity, and location of hazardous substances and the time at
which such substances were stored, released, or disposed of, as defined in section 120(h), is
provided in Exhibit 1, attached hereto and made a part hereof.
B. Description of Remedial Action Taken, if Any, Pursuant to Section 120(h)(3)(A)(i)(III) of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. §
9620(h)(3)(A)(i)(III)): Pursuant to section 120(h)(3)(A)(i)(III) of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. §
9620(h)(3)(A)(i)(III)), a description of the remedial action taken, if any, on the property is
provided in Exhibit 2, attached hereto and made a part hereof.
C. Covenant Pursuant to Section 120(h)(3)(A)(ii) and (B) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (42 U.S.C. § 9620(h)(3)(A)(ii) and (B)):
Pursuant to section 120(h)(3)(A)(ii) and (B) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (42 U.S.C. § 9620(h)(3)(A)(ii) and (B)), the United States
warrants that any additional remedial action found to be necessary after the date of this deed
shall be conducted by the United States.
D. Access Rights Pursuant to Section 120(h)(3)(A)(iii) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (42 U.S.C. § 9620(h)(3)(A)(iii)) and the
Missouri Hazardous Waste Management Facility Part I Permit:
1. Subject to the MHWMFP, This deed (lease) (mortgage) is subject to the restrictions
contained in the following documents:
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a. Access easement dated XXXXXX and recorded XXXXXX, Recorder’s Office of Jackson
County, State of Missouri1; and
b. Missouri Hazardous Waste Management Permit No. MO 9890010524, dated October
6, 1999, as the same may have been modified.
2. Subject to CERCLA Section 120(h)(3)(A)(iii), The United States retains and reserves a
perpetual and assignable easement and right of access on, over, and through the property, to enter
upon the property in any case in which a remedial action or corrective action is found to be necessary
on the part of the United States, without regard to whether such remedial action or corrective action is
on the property or on adjoining or nearby lands. Such easement and right of access includes, without
limitation, the right to perform any environmental investigation, survey, monitoring, sampling, testing,
drilling, boring, coring, test pitting, installing monitoring or pumping wells or other treatment facilities,
response action, corrective action, or any other action necessary for the United States to meet its
responsibilities under applicable laws and as provided for in this instrument. Such easement and right of
access shall be binding on the grantee and its successors and assigns and shall run with the land.
In exercising such easement and right of access, the United States shall provide the grantee or
its successors or assigns, as the case may be, with reasonable notice of its intent to enter upon the
property and exercise its rights under this clause, which notice may be severely curtailed or even
eliminated in emergency situations. The United States shall use reasonable means to avoid and to
minimize interference with the grantee’s and the grantee’s successors’ and assigns’ quiet enjoyment of
the property. At the completion of work, the work site shall be reasonably restored. Such easement and
right of access includes the right to obtain and use utility services, including water, gas, electricity,
sewer, and communications services available on the property at a reasonable charge to the United
States. Excluding the reasonable charges for such utility services, no fee, charge, or compensation will be
due the grantee, nor its successors and assigns, for the exercise of the easement and right of access
hereby retained and reserved by the United States.
In exercising such easement and right of access, neither the grantee nor its successors and
assigns, as the case may be, shall have any claim at law or equity against the United States or any officer
or employee of the United States based on actions taken by the United States or its officers, employees,
agents, contractors of any tier, or servants pursuant to and in accordance with this clause: Provided,
however, that nothing in this paragraph shall be considered as a waiver by the grantee and its
successors and assigns of any remedy available to them under the Federal Tort Claims Act.
II. Assurances Pursuant to Section 120(h)(3)(C)(ii) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (42 U.S.C. § 9620(h)(3)(C)(ii)): Pursuant to section
120(h)(3)(C)(ii) of the Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (42 U.S.C. § 9620(h)(3)(C)(ii)), the United States provides the following response action
assurances:
A. Description and Assurance of Necessary Restrictions on the Use of the Property to Ensure the
Protection of Human Health and the Environment. The following restrictions and covenants,
1 Note: These dates will be inserted at time of transfer of the property.
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including those required by the Missouri Hazardous Waste Management Facility Part I
Permit, shall be placed into the deed:
1. Non-residential Use Restrictions: Grantee and its successors and assigns covenant and
agree that, unless previously approved by the Department of Natural Resources (DNR), the
areas with institutional controls may not be used for any purpose other than industrial use.
Industrial uses are those that result only in exposure of adult workers in industrial,
construction, and maintenance activities consistent with the exposure assumptions in
DOE’s approved Multiple Sites CMS (Administrative Record No. 93) and the exposure
assumptions in the 95th Terrace Site CMS. Further, the use of the Property shall be limited
to non-residential use only. Prohibited residential uses include, but are not limited to, any
form of housing and child care, pre-schools, educational institutions attended on a regular
basis by students younger than 18-years old, and playgrounds, whether or not ancillary to a
commercial facility or endeavor.
2. Public Access/Use Restriction: Grantee and its successors and assigns covenant and agree
that there will be no unauthorized public access or use of Solid Waste Management Unit as
defined by the Missouri Hazardous Waste Facility Management Part I Permit, unless
authorized by the applicable permit and the Grantor. Public access to all contaminated soil
shall be prevented by appropriate means such as fences and other security measures.
3. Ground Disturbance Restrictions:
a. Grantee and its successors and assigns covenant and agree that no physical or
structural changes or disturbances of ground surface shall be permitted in, on, or
immediately adjacent to any Solid Waste Management Unit or Area of Concern as
defined by the Missouri Hazardous Waste Facility Management Pert I Permit, unless
and until authorized by the applicable permit and the Grantor.
b. Any future construction or maintenance activities involving excavation of contaminated
soil shall include internal Permittee controls consistent with Occupational Safety and
Health Administration (OSHA) requirements regarding appropriate worker exposure
protection and shall provide for the management of the soil according to federal, state,
and local regulations.
c. Buildings, structures, and pavement that currently cover contaminated soil shall not be
removed or altered unless the Permittee has provided for alternative corrective
measures to protect human health and the environment, and has the prior approval of
the Department. An exception to this is repair and maintenance of utilities provided
for by the Excavated Soil Management procedures found in Special Permit Condition
XXI.B. Alterations that are subject to this provision are limited to those that result in
exposing presently covered contaminated soils.
4. Notice of the Potential Presence of Radiological Material and Covenants
a. The Grantee is hereby notified that due to the former use of the Property for
Department of Energy operations, the Property may contain Radiological Material
related to DOE Operations. The term Radiological Material means solid, liquid, or
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gaseous material, derived from U.S. Government activities, that contains radio nuclides
regulated under the Atomic Energy Act of 1954, as amended, and licensed by the
Nuclear Regulatory Commission. It includes radioactive material, nuclear devices and
nuclear components thereof, and radiographic and instrument calibration sources and
various instrumentation and radio luminescent products manufactured for military
applications. The term ''Radiological Materials" does not include naturally occurring
background radiation, radio luminescent dials, or products manufactured for non-
military applications, such as radio luminescent signs, tungsten welding electrodes and
household smoke detector components.
b. Based on a review of existing records and a thorough site study, it is considered highly
unlikely that Radiological Material exists on the Property. However, the possibility of
such material being discovered on the property is acknowledged to be possible.
c. Grantee and its successors and assigns agree and covenant that all necessary and
appropriate responses shall be completed per applicable regulations, instructions,
policy and guidance prior to sale, lease, license, or other transfer of possession or
control of the Property or any portion thereof.
d. In the event the Grantee, its successors, and assigns, should discover any Radiological
Material on the Property, Grantee and its successors and assigns covenant and agree
that it shall not attempt to remove or destroy it, but shall immediately contact the DOE
representative who will, as needed, promptly respond, assess and dispose of such
Radiological Material at no expense to the Grantee. The Grantee, or its successors or
assigns, shall: (a) cooperate with the Grantor with regard to the location of and
removal of Radiological Material from the Property, provided such cooperation does
not require the Grantee, or its successors or assigns, to incur any non-reimbursed
direct costs, (b) notify the Grantor as soon as reasonably possible after the discovery of
any Radiological Material by the Grantee, or its successors or assigns, and (c) take no
actions regarding Radiological Material discovered on the Property, except as may be
specifically directed by the Grantor.
5. Groundwater Use Restrictions: Groundwater on the KCP portion of the BFC shall not be
used as a water supply for any purpose.
6. Previously filed Land Use Restrictions are on file with the Jackson County Recorder’s
Office and are included herein at Exhibit 3.
7. Removal or Modification of Use Restrictions: Grantee and its successors and assigns may
petition Grantor for removal or modification of the above Restrictions on the Use of the
Property based upon a showing that the property is suitable for one or more of the above
prohibited uses or a modification of such restrictions. Any such petition must be submitted
to the Grantor in a writing clearly describing the removal or modifications of the
restrictions being requested and the basis for such removal, signed by the property owner
or authorized agent. The request must include the following information:
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a. A legal description of the meets and bounds of the property prepared by a licensed
surveyor and a map showing the property’s location in relation to recognizable
property features, including any areas of contamination.
b. Evidence satisfactory to Grantor that:
i. property is no longer subject regulation by the Hazardous Waste Facility Permit,
and
ii. All land use controls established pursuant to the Missouri Environmental Use
Controls Program have been removed or have been modified consistent with the
requested modifications to these restrictions.
c. Information supporting the requested modifications, including but not limited to
reports, photographs, maps, drawings, and data documenting any sampling an analysis,
testing, survey, remedial action, or data evaluation performed by the Grantee and its
successors and assigns in support of its request.
d. The proposed revised zoning of the property, if applicable.
e. Other information as reasonably requested by the Grantor.
The Grantor may approve, deny, or offer a modification to Grantee’s request. Upon
approval of the request, Grantor shall issue a “Deed of Release” or other appropriate
instrument effecting the removal or modification of the restrictions on the applicable
property. The Property owner shall be responsible for filing of the instrument in the county
land records.
B. Description and assurance of restrictions on use necessary to ensure that required remedial
investigations, response action, and oversight activities will not be disrupted.
1. Non-Disturbance Clause: Grantee and its successors and assigns covenant and agree not
to disrupt and/or prevent the United States of America, its officers, employees, agents,
contractors and subcontractors, and any other authorized party or entity from conducting
any required environmental response, including, but not limited to, investigation, survey,
treatment, remedy, oversight, construction, demolition, decontamination, upgrading,
operating, maintaining, and monitoring.
2. Indemnification: Grantee and its successors and assigns recognize that the conduct of
environmental remediation may result in the removal or destruction of above and below
ground utilities, the interruption of rail traffic, road traffic, and other site activities, and/or
the temporary evacuation of areas in and around these activities. This requirement may
include the removal of or a disruption in the movement of rail cars, trucks, and other
equipment. The United States shall make no payments to Grantee, its successors and
assigns, or their leases, licensees, agents, contractors or subcontractors, guests, or
trespassers as a result of the above, but will use reasonable means to avoid or minimize
interference with Grantee’s and Grantee’s successors’ and assigns’ quiet enjoyment of the
Property, and Grantee and its successors and assigns agree to indemnify the United States
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against all such resulting claims, including but not limited to claims for loss of use,
commercial interruption, destruction of property, and personal injury.
3. Assurance that all necessary response action will be taken and schedule for completion
of all necessary response action:
Environmental contamination on the Property is being addressed under the Missouri
Hazardous Waste Management Facility Part I Permit (MHWMFP) and Administrative Order on Consent
(AOC) currently being negotiated between the State of Missouri and the Grantee. Under the terms of
the MHWMFP and AOC, The Grantee shall be responsible for hazardous waste facility closures and
corrective measures required under the Hazardous Waste Facility Permit with funding provided by
Grantor. Grantor’s obligations to fund closure and corrective measures contained in the MHWMFP are
limited to all releases of hazardous wastes, hazardous substances and pollutants that occurred prior to
the date of the transfer of the Property to the Grantee, or that occur after the date of transfer if caused
by the Grantor or its contractors (“Existing Contamination”). After the date of transfer, the Grantor shall
not be obligated for corrective measures for new releases of hazardous wastes, hazardous substances,
and pollutants unless caused by the Grantor or its contractors (“New Contamination”). The Grantee shall
be responsible for all work required under the Modified MHWMFP and AOC, and all work required to
address New Contamination. Grantee shall perform required work in accordance with the conditions
and schedules set forth in the MHWMFP and AOC as these may be modified from time to time, or as
determined by any agreement between Grantor and Grantee not inconsistent with the MHWMFP and
AOC.
When all response action necessary to protect human health and the environment with
respect to any substance remaining on the property on the date of transfer has been taken, the United
States shall execute and deliver to the transferee an appropriate document containing a warranty that
all such response action has been taken, and the making of the warranty shall be considered to satisfy
the requirement of CERCLA 120(h)(A)(ii)(I).
4. Assurance that the Department of Energy Will Submit a Budget Request to the Director
of the Office of Management and Budget that Adequately Addresses Schedules for
Completion of All Necessary Response Actions and Required Long-Term Operation,
Maintenance, and Monitoring (LTOM&M)
Beginning with the Fiscal Year 2016 appropriation request, the Grantor, through the
Department of Energy, shall annually submit budget requests to the Director of the Office of
Management and Budget that, if appropriated, adequately fund the agreed upon schedule for
investigation and completion of all necessary closure and corrective measures required under the
Missouri Hazardous Waste Management Facility Part I Permit, including LTOM&M, until such time as
that all necessary corrective measures have been completed. The actual amount available for such
activities is subject to congressional authorizations and appropriations.
III. OTHER DEED PROVISIONS:
A. “As Is”
1. The Grantee acknowledges that it has inspected or has had the opportunity to inspect the
Property and accepts the condition and state of repair of the subject Property. The
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Grantee understands and agrees that the Property and any part thereof is offered “AS IS”
without any representation, warranty, or guaranty by the Grantor as to quantity, quality,
title, character, condition, size, or kind, or that the same is in condition or fit to be used
for the purpose(s) intended by the Grantee, and no claim for allowance or deduction upon
such grounds will be considered.
2. No warranties, either express or implied, are given with regard to the condition of the
Property, including, without limitation, whether buildings on the Property do or do not
contain hazardous material such as, but not limited to, asbestos or lead-based paint. The
Grantee shall be deemed to have relied solely on its own judgment in assessing the overall
condition of all or any portion of the Property, including, without limitation, any asbestos,
lead-based paint, or other conditions on the Property. The failure of the Grantee to
inspect or to exercise due diligence to be fully informed as to the condition of all or any
portion of the Property offered, will not constitute grounds for any claim or demand
against the United States.
3. Nothing in the “As Is” provision will be construed to modify or negate the Grantor’s
obligation under the CERCLA Covenant or any other statutory obligations.
B. POST-TRANSFER DISCOVERY OF CONTAMINATION
1. If an actual or threatened release of a hazardous substance or petroleum product is
discovered on the Property after the date of conveyance, Grantee, its successors or
assigns, shall be responsible for such release or newly discovered substance unless
Grantee is able to demonstrate that such release or such newly discovered substance was
due to Grantor’s activities, use, or ownership of the Property. If the Grantee, it successors
or assigns believe the discovered hazardous substance is due to Grantor’s activities, use or
ownership of the Property, Grantee will promptly secure the site and notify the Grantor of
the existence of the hazardous substances, and Grantee will not further disturb such
hazardous substances without the written permission of the Grantor.
2. Grantee, its successors and assigns, as consideration for the conveyance of the Property,
agree to release Grantor from any liability or responsibility for any claims arising solely out
of the release of any hazardous substance or petroleum product on the Property occurring
after the date of the delivery and acceptance of this Deed, where such substance or
product was placed on the Property by the Grantee, or its successors, assigns, employees,
invitees, agents or contractors, after the conveyance. This paragraph shall not affect the
Grantor’s responsibilities to conduct response actions or corrective actions that are
required under the CERCLA Covenant and by applicable laws, rules, permits and
regulations.
C. ENVIRONMENTAL PROTECTION PROVISIONS
The Modified Missouri Hazardous Waste Management Facility Part I Permit contains a
requirement that Grantee must complete an Environmental Land Use Covenant within 60 days of
transfer. The Grantee shall neither transfer the property, lease the property, nor grant any interest,
privilege, or license whatsoever in connection with the property without the inclusion of the
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Environmental Protection Provisions contained herein or in the Environmental Land Use Covenant, and
shall require the inclusion of these Environmental Protection Provisions in all further deeds, easements,
transfers, leases, or grant of any interest, privilege, or license.
Exhibit 1, Page 1 of 7
Exhibit 1
Hazardous Substances Stored and/or Released at the Bannister Federal Complex
The list of hazardous substances stored and released on a property is typically provided to the new
owner of a property being transferred out of the Federal inventory to aid in understanding the types of
hazardous constituents that may be found in the soil and/or groundwater at the site. This information is
most helpful when dealing with a site where little investigation has been conducted and little is known
about the environmental condition of the property. The Bannister Federal Complex has been used as an
industrial facility since 1943. As a result, a wide variety of chemicals and hazardous substances have
been stored and used as the site. Unfortunately, records regarding chemical storage at the site are not
available for the first 40-plus years of operation prior to the Superfund Amendments and
Reauthorization Act of 1986, when annual reporting of chemical storage in excess of established
threshold planning quantities became a requirement. For those early years of manufacturing operations
at the site, much of the information on chemical usage is only available through anecdotal evidence,
findings of investigations of environmental releases, known above ground and below ground tank
storage of chemicals and tank capacities, and process knowledge. Table 1 presents the consolidated list
of hazardous substances stored at the BFC in excess of modern threshold planning quantities. The last
two columns of the table indicate whether the source of the data is from SARA reports or from
anecdotal evidence, storage capacities, or results of site investigations.
With regard to the release of hazardous substances, the Bannister Federal Complex has been extensively
characterized through investigations conducted by both the current owner as part of the NNSA’s
ongoing environmental remediation program, and by the new owner of the property to be transferred
as part of their pre-transfer due diligence efforts. As a result, a great deal is known about the hazardous
constituents that have impacted the environment over the past 70+ years of manufacturing operations
conducted at the BFC. Table 2 provides a summary of the information on hazardous constituents found
at the site through these past characterization activities, as well as information on documented historic
releases of hazardous substances at the Bannister Federal Complex.
Table 1. Consolidated List of Hazardous Substances Stored at the BFC
Chemical Name CAS # Storage Quantity
Range (lbs.)
(Note: SARA reporting
ranges used. Highest
reported value since
1986 is listed.)
SARA
Report
Anecdotal,
Storage
Capacity, or
Investigation
Findings
Acetic Acid 64-19-7 10,000 – 24,999 X
Acetone 67-64-1 10,000 – 24,999 X
Ammonia 7664-41-1 1,000 – 4,999 X
Argon (liquefied) 7440-37-1 100,000 – 499,999 X
Exhibit 1, Page 2 of 7
Chemical Name CAS # Storage Quantity
Range (lbs.)
(Note: SARA reporting
ranges used. Highest
reported value since
1986 is listed.)
SARA
Report
Anecdotal,
Storage
Capacity, or
Investigation
Findings
Boron 10 14798-12-0 1,000 – 4,999 X
Cadmium Oxide 1306-19-0 100 – 499 X
Calcium Hydroxide 1305-62-0 25,000 – 49,999 X
Carbon & Carbon Dust 7440-44-0 1,000 – 4,999 X
Carbon Dioxide 124-38-9 50,000 - 74,999 X
Chlorine (gas) 7782-50-5 500 – 999 X
Chlorodifluoromethane 75-45-6 10,000 – 24,999 X
Chloroform 67-66-3 500 – 999 X
Cyclohexylamine 108-91-8 5,000 – 9,999 X
Dichlorodifluoromethane 75-71-8 10,000 – 24,999 X
Diesel Fuel, #2 68476-34-6 1,000,000 – 9,999,999 X
Dimethylformamide 68-12-2 10,000 – 24,999 X
Diphenylmethane Diisocyanate 26447-40-5 10,000 – 24,999 X
Ethylene Diamine 107-15-3 500 – 999 X
Ferrous Sulfate 7720-78-7 10,000 – 24,999 X
Fluoboric Acid 14874-70-5 10,000 – 24,999 X
Formaldehyde 50-00-0 1,000 – 4,999 X
Fuel Oil, #6 68476-33-5 >10,000,000 X
Graphite 7782-42-5 10,000 – 24,999 X
Highly Refined Petroleum Oils 64742-54-7 10,000 – 24,999 X
Hydrochloric Acid 7647-01-0 50,000 - 74,999 X
Hydrofluoric Acid 7664-39-3 1,000 – 4,999 X
Hydrogen Peroxide 7722-84-1 10,000 – 24,999 X
Exhibit 1, Page 3 of 7
Chemical Name CAS # Storage Quantity
Range (lbs.)
(Note: SARA reporting
ranges used. Highest
reported value since
1986 is listed.)
SARA
Report
Anecdotal,
Storage
Capacity, or
Investigation
Findings
Isocyanic Acid,
polymethylenepolyphenylene ester
9016-87-9 1,000 – 4,999 X
Lead 7439-92-1 25,000 – 49,999 X
Methylene Chloride 75-09-2 50,000 - 74,999 X
4,4’-Methlenediphenyl
Di-isocyanate
101-68-8 1,000 – 4,999 X
Mineral Oil 8012-95-1 10,000 – 24,999 X
Nitric Acid 7697-37-2 10,000 – 24,999 X
Nitrobenzene 98-95-3 500 – 999 X
Nitrogen (liquid & gas) 7727-37-9 100,000 – 499,999 X
Phenol 108-95-2 0 – 99 X
Phenol, polymer with formaldehyde 9003-35-4 25,000 – 49,999 X
Phosphoric Acid 7664-38-2 10,000 – 24,999 X
Potassium Cyanide 151-50-8 1,000 – 4,999 X
2-Propanol 67-63-0 50,000 - 74,999 X
Rock Salt 7647-14-5 1,000,000 – 9,999,999 X
Sand 14808-60-7 500,000 – 999,999 X
Sodium Cyanide 143-33-9 1,000 – 4,999 X
Sodium Hydroxide 1310-73-2 50,000 - 74,999 X
Sulfur Dioxide 7446-09-5 1,000 – 4,999 X
Sulfuric Acid 7664-93-9 100,000 – 499,999 X
Tetrafluoroethane (HFC-134a) 811-97-2 25,000 – 49,999 X
Toluene 108-88-3 10,000 – 24,999 X
Toluene 2,4-diisocyanate 584-84-0 10,000 – 24,999 X
Exhibit 1, Page 4 of 7
Chemical Name CAS # Storage Quantity
Range (lbs.)
(Note: SARA reporting
ranges used. Highest
reported value since
1986 is listed.)
SARA
Report
Anecdotal,
Storage
Capacity, or
Investigation
Findings
Toluene 2,6-diisocyanate 91-08-7 100 – 499 X
1,1,1-Trichloroethane 71-55-6 100,000 – 499,999 X
Trichloroethylene 79-01-6 100,000 – 499,999 X
1,1,2-Trichlorotrifluoroethane 76-13-1 100,000 – 499,999 X
1,1,1-Trichlorotrifluoroethane 354-58-5 1,000 – 4,999 X
Urea 57-13-6 10,000 – 24,999 X
Xylene 1330-20-7 10,000 – 24,999 X
Coolants, machining -- 100,000 – 499,999 X
Fuel Grade JP-4 Jet Fuel -- 1,000,000 – 9,999,999 X
Gasoline 86290-81-5 1,000,000 – 9,999,999 X
Hydraulic Oil -- 50,000 – 99,999 X
Kerosene 8008-20-6 100,000 – 499,999 X
Paraffin 8002-74-2 X
Polychlorinated Biphenyl (Aroclor 1242)
53469-21-9 25,000 – 49,999 X
Polychlorinated Biphenyl (Aroclor 1260)
11096-82-5 10,000 – 24,999 X
Uranium, Natural and Depleted 7440-61-1 10,000 – 24,999 X
Uranium Oxide 1344-58-7 10,000 – 24,999 X
Waste, Acid -- 50,000 - 74,999 X
Waste, Alkaline -- 50,000 - 74,999 X
Waste, Oil -- 100,000 – 499,999 X
Waste, PCB -- 10,000 – 24,999 X
Waste, Solvent -- 100,000 – 499,999 X
Exhibit 1, Page 5 of 7
Table 2. Hazardous Substance Releases and Hazardous Constituents Found at the BFC.
Contaminant CAS No. Site
Investigation
Finding
Documented
Spill*
Comments
Acetone 67-64-1 X
Aroclor 1242 (PCB) 53469-21-9 X X 900 gallon spill to
stormwater outfall 002 on
11/10/69.
1114 gallon spill to
stormwater outfall 002 on
10/27/72.
Aroclor 1254 (PCB) 11097-69-1 X Degradation product of
Aroclor 1260. Arolclor 1254
not used/stored on site.
Aroclor 1260 (PCB) 11096-82-5 X X Transformer spill on roof.
Quantity and date unknown.
Benzene 71-43-2 X Constituent of other
compounds released onsite.
2-Butanone 78-93-3 X Constituent of other
compounds released onsite.
Carbon Disulfide 75-15-0 X
Chlorobenzene 108-90-7 X Constituent of other
compounds released onsite.
Chloroethene (Vinyl
Chloride)
75-01-4 X Degradation product of
other compounds released
onsite.
Chloroform 67-66-3 X
1,2-Dichlorobenzene 95-50-1 X Constituent of other
compounds released onsite.
1,3-Dichlorobenzene 541-73-1 X Constituent of other
compounds released onsite.
1,4-Dichlorobenzene 106-46-7 X Constituent of other
compounds released onsite.
Exhibit 1, Page 6 of 7
Contaminant CAS No. Site
Investigation
Finding
Documented
Spill*
Comments
1,1-Dichloroethane 75-34-3 X Degradation product of
other compounds released
onsite.
1,2-Dichloroethane 107-06-2 X Degradation product of
other compounds released
onsite.
1,1-Dichloroethene 75-35-4 X Degradation product of
other compounds released
onsite.
1,2-Dichloroethene
(total)
156-59-2
156-60-5
X Degradation product of
other compounds released
onsite.
Ethylbenzene 100-41-4 X Constituent of other
compounds released onsite.
4-Methyl-2-Pentanone 108-10-1 X
Tetrachloroethene 127-18-4 X
Toluene 108-88-2 X
1,1,1-Trichloroethane 71-55-6 X
1,1,2-Trichloroethane 79-00-5 X
Trichloroethene 79-01-6 X
Trichlorofluoromethane 75-69-4 X
1,1,2-Trichloro-1,2,2-
trifluoroethane
76-13-1 X
Xylenes (total) 95-47-6
108-38-3
106-42-3
X
Chemically treated
cooling tower water
-- X 2,000 gallons of cooling
tower water containing
corrosion inhibitors and
Exhibit 1, Page 7 of 7
Contaminant CAS No. Site
Investigation
Finding
Documented
Spill*
Comments
algicide spilled to storm
sewer on 5/3/1986.
Chromic Acid 7738-94-5 X 10 gallons spilled to ground
12/11/97. An unknown
amount spilled to 002 on
4/25/63.
Cyanide Rinsewater,
Dilute
-- X 100 gallons spilled to ground
on 12/21/1996.
Fuel Oil, #6 68476-33-5 X 200 gallons spilled to ground
on 1/4/74 and 1/12/90.
Unknown quantities spilled
to ground on 8/19/64 and
12/11/66.
Groundwater -- X 50-300 gallons spilled to
ground on 5/1/97, 7/1/98,
and 8/18/98.
Hydraulic Oil -- X 40 gallons spilled to ground
on 4/24/96.
Industrial Wastewater -- X Spills of unknown quantities
to ground or stormwater
collection system on 2/8/63,
1/20/76, 8/4/83, 9/19/83,
10/8/83, 2/21/85, and
3/9/86.
Nitric Acid 7697-37-2 X 100 gallon spill to ground on
12/21/77.
Oil/coolant mixture -- X 3,248 gallons spilled to
ground 0n 5/19/81.
Sodium Hypochlorite 7681-52-9 X 150 gallons spilled to storm
sewer 12/12/84.
Sulfuric Acid 7664-93-9 X 1,650 gallons spilled to the
storm sewer 1/29/63.
*Additional information regarding the documented releases on the site can be found in Section 4, Table
4.1 of the Bannister Federal Complex Description of Current Conditions Report.
Exhibit 2, Page 1 of 15
Exhibit 2.
Bannister Federal Complex Corrective Action List and Status
Following is the list of corrective actions performed at the Bannister Federal Complex in addressing the 44 solid waste management units (SWMU) that have been identified as tied to the property to be transferred from the NNSA to Bannister Transformation & Development, LLC. A brief description of the actions taken and the regulatory status of each SWMU is provided. More detailed information regarding the investigations conducted, the results of those investigations, and the corrective actions executed can be found in Sections 4 and 5 of the Bannister Federal Complex Description of Current Conditions Report.
Solid Waste Management
Unit (SWMU) # REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
SWMU 1
Underground Tank Farm
The Underground Tank Farm was closed under RCRA in 1987. Closure was completed in 1988 by removing soil to a depth of approximately fifteen feet (roughly the depth of the water table), removal of all tanks, associated piping, concrete supports and unloading stations, backfilling with uncontaminated soil, and covering the site with a clay cap, topsoil and vegetation.
Active RCRA Corrective Action Complete. Approval of RCRA closure and post closure care received in a 12/16/1988 letter from MDNR. Post closure activities include inspection and maintenance of protective cap and cover. Continued groundwater monitoring and pump and treat. Post closure care activities implemented and ongoing. No further regulatory approval required.
Ongoing RCRA post closure care. Inspection and maintenance of protective cap and cover. Continued Institutional and Engineering Controls as defined in Sitewide Institutional Controls Plan as contained in the Long Term Operations Maintenance and Monitoring Plan. Continued groundwater monitoring and pump and treat. Access and Deed Restrictions.
SWMU 2
TCE Still Location
A solvent recovery still operated in this area in the 1950’s. Solvent spills have contaminated soil and groundwater. Interim Measures completed in FY98 included removal of concrete slab and soil to 5 feet, removal of abandoned piping, and backfill of area with clean soil. Institutional controls and groundwater pump and treat implemented.
Active RCRA Corrective Action Complete. Unit a part of Multi-site CMS Final Decision issued July 15, 1998. CMI work plan outlining institutional controls, continued monitoring and groundwater pump and treat was approved by MDNR in a letter dated November 6, 2000. Remedy is implemented and ongoing. No further regulatory approval required.
Continued Institutional and Engineering Controls as defined in Sitewide Institutional Controls Plan. Continued groundwater monitoring and pump and treat. Access and Deed Restrictions.
Exhibit 2, Page 2 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
SWMU 3
Waste Transfer
Spill Area
Liquid wastes transferred to two holding tanks
(unknown duration). Alleged routine spills. No
evidence of release found in RFI.
Combined and addressed with SWMU 37
(Abandoned Sump). Soil removed to 15’ and
backfilled with clean soil. Institutional controls
and groundwater pump and treat
implemented.
Active RCRA Corrective Action Complete.
Investigated under TCE Still Area RFI. Unit a
part of Multi-site CMS Final Decision issued
July 15, 1998. Selected remedy is institutional
controls for soils with groundwater pump and
treat. CMI work plan outlining institutional
controls, continued monitoring and
groundwater pump and treat was approved by
MDNR in a letter dated November 6, 2000. No
further regulatory approval required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 4
Classified Waste
Trenches
Three former burial trenches excavated in
1984. Debris removed and disposed of off-
site. Excavation backfilled with clean soil.
Institutional controls and groundwater pump
and treat implemented.
Active RCRA Corrective Action Complete.
Investigated under TCE Still Area RFI. Unit a
part of Multi-site CMS Final Decision issued
July 15, 1998. Selected remedy is institutional
controls for soils with groundwater pump and
treat. CMI work plan outlining institutional
controls, continued monitoring and
groundwater pump and treat was approved by
MDNR November 6, 2000. No further
regulatory approval required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 5
North Lagoon
An industrial wastewater lagoon in service
from 1963 to 1985. Sludge was removed in
1985 and area backfilled with clean soil and
capped in 1988 as a part of RCRA closure.
Institutional and engineering controls and
groundwater pump and treat implemented.
Active RCRA Corrective Action Complete.
Hazardous Waste Management Unit in post-
closure care. Approval of RCRA closure and
post closure care received in a 12/16/1988
letter from MDNR. Unit also included in
Northeast Area investigation. CMI Workplan
for Northeast Area approved by EPA 10/29/96.
Ongoing RCRA post closure care. Inspection
and maintenance of protective cap and cover.
Continued Institutional and Engineering
Controls as defined in Institutional Controls
Plan. Continued groundwater monitoring and
pump and treat. Access and Deed Restrictions.
Exhibit 2, Page 3 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
Post closure care and institutional and
engineering controls with groundwater pump
and treat implemented and ongoing. No
further regulatory approval required.
SWMU 6
Old Ponds
Three ponds identified on historical aerial
photographs. Addressed under corrective
action. Identified as primary source of
Northeast Area contamination. Groundwater
pump and treat and institutional controls
implemented.
Active RCRA Corrective Action Complete.
Corrective Measure Study approved 11/13/95.
Final Decision/Response to Comments issued
11/13/95 – Institutional controls with
groundwater pump and treat. CMI workplan
approved by EPA10/29/96. Implementation of
remedy ongoing. No further regulator
approval required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 7
North Lagoon
Trench Area
Trench and reinforced concrete pipe found
under the base of the Former North Lagoon. It
was rerouted when the lagoon was
constructed. An excavation in this trench
revealed the RCP, an empty TCE drum and
other miscellaneous items which were
removed and disposed offsite. The excavation
was backfilled with clean soil and capped as
part of the North Lagoon closure (SWMU 5.)
Active RCRA Corrective Action Complete
Corrective Measures Study approved
11/13/95. Final Decision/Response to
Comments issued 11/13/95 - Institutional
controls with groundwater pump and treat.
CMI Workplan approved by EPA 10/29/96.
Implementation of remedy ongoing. No
further regulatory approval required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 8
Outfall 001
Raceway
Volatile organic contamination at this location
derived from groundwater seeps.
Groundwater collection system installed in
April 1993.
Corrective Measures Study approved
11/13/95. Final Decision/Response to
comments issued 11/13/95. CMI Workplan
approved by EPA 10/29/96 that required
operation of 001 Interceptor System under
Continued Institutional and Engineering
Controls as defined in the Sitewide
Institutional Controls Plan. Includes continued
operation and maintenance of Outfall
001groundwater collection sump. Continued
Exhibit 2, Page 4 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
GW Treatment System Operations and
Maintenance plan. Remedy implemented and
ongoing. No further regulatory approval
required.
groundwater monitoring and pump and treat.
Access and Deed Restrictions.
SWMU 9
Building 57 Acid
and Alkaline
Tanks
Acid and alkaline tanks attached to an old
plating facility. Corrective action determined
that area was not a release site. Tanks and
ancillary piping removed. Institutional
controls and pump and treat implemented.
Active RCRA Corrective Action Complete.
Tanks removed in 1989. Tank sumps removed
in 1996 under Interim Measures. Unit a part
of Multi-site CMS approved July 15, 1998.
Selected remedy is institutional controls for
soils with groundwater pump and treat. CMI
workplan was approved by MDNR November
6, 2000. Remedy implemented and ongoing.
No further regulatory approval required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 10
Waste Oil Tank
Under North
End of Plating
Building
A 26,000 gallon tank used for waste oil. Tank
was installed in 1943 and used until 1950.
Tank removed and excavation backfilled with
clean soil in 1995 under Interim measures.
Groundwater pump and treat and institutional
controls for soils implemented.
Active RCRA Corrective Action Complete. Unit
a part of Multi-site CMS. Final Decision issued
July 15, 1998. Selected remedy is institutional
controls for soils with groundwater pump and
treat. CMI work plan was approved by MDNR
November 6, 2000. Remedy implemented and
ongoing. No further regulatory approval
required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 11
Substation 18
North of Plating
Building
Electrical substation containing Aroclor 1260
from which spills may have occurred.
Transformer and concrete pad removed.
Active RCRA Corrective Action Complete.
Electrical equipment removed in 1989.
Substation spill containment removed in 1995.
Addressed under Interim Measures. Interim
Measures Report approved by EPA 12/21/95.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
Exhibit 2, Page 5 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
CMI work plan describing institutional controls
to be implemented was approved by MDNR
November 6, 2000. Remedy implemented and
ongoing. No further regulatory approval
required.
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 12
Department 26
Outside
Site of former Therminol heat transfer system.
Three Therminol tanks and piping removed in
1985. Contaminated soil above storm sewer
laterals removed under Interim Measures in
1996. Groundwater pump and treat and
institutional controls for soils implemented.
Active RCRA Corrective Action Complete. Unit
a part of Multi-site CMS Final Decision issued
July 15, 1998. Selected remedy is institutional
controls for soils with groundwater pump and
treat. CMI work plan was approved by MDNR
November 6, 2000. Remedy implemented and
ongoing. No further regulatory approval
required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 13
South Lagoon
An industrial wastewater lagoon in service
from 1975 to 1988. A RCRA Closure was
completed in 1988 which included removing
contaminated sediments, backfilling with
uncontaminated soil, and covering the site
with a clay cap, topsoil and vegetation.
Active RCRA Corrective Action Complete. Final
closure report and post closure care plan
approved by MDNR in a letter dated 12/16/98.
RFI performed under RCRA 3008(h) Consent
Order. No further action for groundwater as
contamination is below remediation goals
based on MDNR approval of South Lagoon RFI
Report November 13, 1995. Ongoing post-
closure care under RCRA consisting of cap
maintenance and institutional controls. No
further regulatory approval required.
Ongoing RCRA post closure care. Inspection
and maintenance of protective cap and cover.
Access and Deed Restrictions
SWMU 14 Outfall prior to construction of Highway W
(Bannister Road). PCB spills contaminated the
Active RCRA Corrective Action Complete.
Corrective Measure Implementation (CMI)
Exhibit 2, Page 6 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
Old 002 Storm
Sewer Outfall
(AICO)
Outfall area, and then were buried during
highway construction. A large PCB remedial
project was undertaken in 1993 at AICO where
27,210 tons of PCB contaminated material (up
to 9,000 mg/kg) were removed for off-site
disposal. Clean fill was used to restore the area
to grade. RCRA Corrective Action completed.
completed. Confirmation study approved by
EPA Region VII on 8/12/94.
No further action.
SWMU 15
New 002 Storm
Sewer Outfall
Present location of storm water discharge to
Indian Creek. PCB contaminated soil
historically located in and around the Outfall.
Soil removed, backfilled with clean soil. Barrier
installed to prevent access to discharge
raceway. Institutional and engineering
controls implemented.
Active RCRA Corrective Action Complete.
Contaminated soil along bank of Indian Creek
removed to EPA Region VII prescribed levels
and covered with clean backfill (1988).
Approved for no further action under Consent
Order. Re-addressed as a part of the 95th
Terrace Project. Remedy includes institutional
and engineering controls with continued
monitoring. All monitoring and controls are
implemented and ongoing. CMI workplan
submitted.
See SWMU 42.
SWMU 16
Sales Building
Building was used from mid-1940’s to 1972 to
store surplus equipment for sale. Degreasing
solvents may have been used. Groundwater
contamination is present in the area.
Institutional controls implemented.
Active RCRA Corrective Action Complete. Unit
a part of Multi-site CMS. Final Decision issued
July 15, 1998. Selected remedy is institutional
controls for soils with groundwater pump and
treat. CMI work plan was approved by MDNR
November 6, 2000. Remedy implemented and
ongoing.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
Exhibit 2, Page 7 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
SWMU 17
Building 54
Oil seeping through a wall in the basement of
this building caused it to be added to the prior
Consent Order. A sump was later determined
to be located outside the building near the
leak. Investigation, revealed no widespread
contamination. Institutional controls and
pump and treat implemented.
Active RCRA Corrective Action Complete. Unit
a part of Multi-site CMS. Final Decision issued
July 15, 1998. Selected remedy is institutional
controls for soils with groundwater pump and
treat. CMI work plan was approved by MDNR
November 6, 2000. Remedy implemented and
ongoing. No further regulatory approval
required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 18
North Lot
Historical aerial photos indicate drums and
equipment in this area. No contamination
found at this location. No remedial action
required.
Active RCRA Corrective Action Complete. RFI
for Miscellaneous Contaminated Soils found no
contamination. EPA approved the
Miscellaneous Contaminated Soils CMS on
11/13/95, which removed this SWMU from
further consideration.
No further action.
SWMU 19
Building 16
Underground Pit
A pit which may have received spills of PCBs
from cleaning operations. No remedial action
required.
Active RCRA Corrective Action Complete. RFl
for Miscellaneous Contaminated Soils found no
contamination. EPA approved the
Miscellaneous Contaminated Soils CMS on
11/13/95, which removed this SWMU from
further consideration.
No further action.
SWMU 20
Abandoned Fuel
Lines
Fuel lines from the old Underground Tank
Farm, which may contain residual fuel/oil.
Addressed as a part of Miscellaneous
Contaminated Soils. BFEC 31 investigated as a
part of Abandoned Fuel Lines investigation
Active RCRA Corrective Action Complete. Final
remedy of institutional controls chosen in Final
Decision/ Response to Comments for
Miscellaneous Contaminated Soils. CMI
Workplan approved by EPA 10/29/96. Remedy
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions
Exhibit 2, Page 8 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
(borehole 18). Institutional controls
implemented.
implemented and ongoing. No further
regulatory approval required.
SWMU 21
Fuel Oil Tank
Unloading Area
Unloading area for two 400,000 gallon fuel oil
tanks. Addressed as a part of Miscellaneous
Contaminated Soils. Institutional controls
implemented.
Active RCRA Corrective Action Complete.
Final remedy of institutional controls chosen in
Final Decision/Response to Comments For
Miscellaneous Contaminated Soils. CMI
Workplan approved by EPA 10/29/96. Remedy
implemented and ongoing. No further
regulatory approval required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 22
East of Oil
Storage Tanks,
Underground
Tank Farm and
Building 15,
Extending to
Lagoons
PCB contaminated water was spread on the
ground in this area. Sampling prior to 1989
indicated no significant contamination,
allowing the site to be approved for no further
action. No remedial action required.
Assigned no further action in Appendix E of
the prior RCRA 3008(h) Consent Order dated
June 23, 1989.
No Further Action
SWMU 23
PCB and
Hydraulic Oil
Spills in Open
Area East of
Barrel Lot
Water contaminated with PCBs and hydraulic
oil was dumped on ground. Sampling prior to
1989 indicated no significant contamination,
allowing the site to be approved for no further
action. No remedial action required.
Assigned no further action in Appendix E of
prior (June 23, 1989) RCRA 3008(h) Consent
Order.
No Further Action
Exhibit 2, Page 9 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
SWMU 24
Wastewater
Dumping West
of
Building 16
Dilute waste acids, caustics, water from spills
and sumps (some containing oils), and PCBs
were dumped onto the ground and allowed to
infiltrate into soil. Sampling prior to 1989
indicated no significant contamination,
allowing the site to be approved for no further
action when the prior Consent Order was
signed. No remedial action required.
Assigned no further action in Appendix E of
prior (June 23, 1989) RCRA 3008(h) Consent
Order.
No Further Action
SWMU 25
Spill of Cutting
Oil and Coolants
Near Lot 187-1
Outside Diked
Area
Cutting oil and coolants were spilled, routed to
an unlined concrete sump and pumped out.
Sampling prior to 1989 indicated no significant
contamination, allowing the site to be
approved for no further action when the prior
Consent Order was signed. No remedial action
required.
Assigned no further action in Appendix E of
prior (June 23, 1989) RCRA 3008(h) Consent
Order.
No Further Action
SWMU 26
Spill of Caustic
Wastewater
North of
Manufacturing
Support Building
Caustic wastewater from a leaking pipe spilled
into an excavation. Approved for no further
action when prior Consent Order was signed.
No sampling performed. No remedial action
required.
Assigned no further action in Appendix E of
prior (June 23, 1989) RCRA 3008(h) Consent
Order.
No Further Action
Exhibit 2, Page 10 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
SWMU 27
Dumping of
PCB
contaminated
wastewater
west of lagoons
Sampling indicated no significant
contamination. Approved for no further
action when prior Consent Order was signed.
No remedial action required.
Assigned no further action in Appendix E of
prior (June 23, 1989) RCRA 3008(h) Consent
Order.
No Further Action
SWMU 28
Spill of Plating
Acid From
Truck
(East Half of
Barrel Lot)
Approximately 3000 gallons of acid was
spilled onto gravel and covered with sodium
carbonate. Sampling indicated no significant
contamination. Approved for no further
action when prior Order was signed. No
remedial action required.
Assigned no further action in Appendix E of
prior (June 23, 1989) RCRA 3008(h) Consent
Order.
No Further Action
SWMU 29
Southeast
Parking Lot
Construction waste was dumped here leading
to the concern that hazardous/toxic materials
may have been dumped as well. Groundwater
pumping wells installed to prevent offsite
migration of plume.
Active RCRA Corrective Action Complete.
Assigned no further action in Appendix E of
prior RCRA 3008(h) Consent Order. However,
the 1999 MHWMF Permit required a Phase I
RFI which was subsequently approved by
MDNR on August 28, 2000. Approval requires
continued operation of groundwater pump
and treat system. Remedy implemented and
ongoing. No further regulatory approval
required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
Exhibit 2, Page 11 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
SWMU 30
Department 27
Outside
Piping, an underground gasoline tank, and
two underground tanks supporting
Department 27 Therminol system. One
project removed tanks, piping and most
contamination. Another removed remaining
soil contamination. Excavation backfilled with
clean soil and asphalt topping applied.
Approved for no further action based on EPA
approval of Interim Measures
Implementation Report November 13, 1995.
No further Action
SWMU 31
Department 26
Active manufacturing department with heat
transfer equipment, which formerly
contained PCB fluids. System was replaced in
mid-1980’s with non-PCB fluids. Leaks from
sumps prior to system replacement have
contaminated soil and groundwater in and
around department. Institutional and
engineering controls implemented.
Active RCRA Corrective Action Complete.
Unit a part of Multi-Sites Final Decision issued
July 15, 1998. CMI Workplan approved by
MDNR on November 6, 2000. Selected
remedy is institutional controls. However,
PCB contaminated soils continue to infiltrate
into 002 storm sewer system. Base flows in
storm sewer have been re-routed to the
groundwater treatment system. PCB
stormwater contamination issues addressed
in 95th Terrace Project. Remedy implemented
and ongoing. No further regulatory approval
required for this SWMU.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions. Reroute of baseflows from
002 storm sewer system.
SWMU 32
Department 27
Inside
Inactive manufacturing department with heat
transfer equipment, which formerly
contained PCB fluids. System was replaced in
mid-1980’s with current, non PCB fluids.
Leaks from pits were suspected but not found
upon investigation. Concrete flooring and
topping, pits, sump, soils, and underground
Active RCRA Corrective Action Complete.
Unit a part of Multi-Sites Final Decision issued
July 15, 1998. Selected remedy is institutional
controls for soils. CMI workplan approved by
MDNR November 6, 2000. Remedy
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
Exhibit 2, Page 12 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
piping removed. Area backfilled with clean
soil and new concrete flooring. Institutional
and engineering controls implemented.
implemented and ongoing. No further
regulatory approval required.
SWMU 33
Oil House
Building used to store oil and other fluids.
Floor drains formerly routed to a French Drain
outside the building caused contamination in
soil and groundwater. Institutional controls
and pump and treat implemented.
Active RCRA Corrective Action Complete.
Unit a part of Multi-Sites Final Decision issued
July 15, 1998. Selected remedy is institutional
controls for soils with groundwater pump and
treat. CMI workplan approved by MDNR
November 6, 2000. Remedy implemented and
ongoing. No further regulatory approval
required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 34
Sanitary Sewer
Pump Station
Sanitary sewer pipe vent where oil discharged
from vent during high flows. Soil indicated
low levels of PCBs initially. No oil or PCBs in
subsequent sampling. No remedial action
required.
Approved for no further action based on
D/27 Outside RFI report (Appendix E of prior
RCRA 3008(h) Consent Order). No further
regulatory approval required.
No further Action
SWMU 35
East
Boilerhouse
Substation 23 and underground electrical lines
near the East Boilerhouse were contaminated
with PCBs. Interim measures removed
electrical equipment, lines, concrete slabs,
and other contamination in 1994/1995.
Active RCRA Corrective Action Complete.
Area addressed under Interim Measures. I/M
Report approved by EPA/MDNR on 3/20/97.
No further regulatory approval required.
No further Action
SWMU 36 Sump where plant vehicles were washed.
Sump leaked liquids to soil and groundwater
Active RCRA Corrective Action Complete. Unit
a part of Multi-Sites Final Decision issued July
15, 1998. Selected remedy is institutional
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
Exhibit 2, Page 13 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
Maintenance
Vehicle Repair
Shop Sump
under sump. Institutional controls
implemented.
controls for soils. CMI workplan approved by
MDNR November 6, 2000. Remedy
implemented and ongoing. No further
regulatory approval required.
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 37
Abandoned
Sump
Sump located between Buildings 89 and 96,
immediately east of Waste Transfer Spill Area
and covered with a large concrete slab.
Combined with SWMU 3 in TCE Still Area RFI.
Interim Measures conducted in FY98 included
removal of concrete slab, sump, and soil, and
backfilling with clean soil. Institutional
controls and pump and treat implemented...
Active RCRA Corrective Action Complete.
Unit a part of Multi-Sites Final Decision issued
July 15, 1998. Selected remedy is institutional
controls for soils with groundwater pump and
treat. CMI workplan approved by MDNR
November 6, 2000. Remedy implemented
and ongoing. No further regulatory approval
required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 38
Reported
Buried Drum
Site
Employee interviews reported burial of
approximately 20 drums thought to have
contained water and black metal shavings
from a previous manufacturing operation.
Ground-penetrating radar, electromagnetic,
and magnetometer surveys were used to
locate. Never found. Presumed non-existent
and was approved for no further action.
No further action based on Results of TCE Still
Area RFI Report (Appendix E).
No further Action
SWMU 39
Department 95
Located in the northeast quadrant of the Main
Manufacturing Building. The area was used for
machining operations including degreasing.
RFI Report approved. No source
contamination identified. Institutional
Active RCRA Corrective Action Complete.
Unit a part of Multi-Sites Final Decision issued
July 15, 1998. Selected remedy is institutional
controls for soils with groundwater pump and
treat. CMI workplan approved by MDNR
November 6, 2000. Remedy implemented
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
Exhibit 2, Page 14 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
controls and groundwater pump and treat
implemented.
and ongoing. No further regulatory approval
required.
SWMU 40
Former Chip
Handling
Building
Formerly located north of the Main
Manufacturing Building. Used to store and
recycle chips from manufacturing processes.
Institutional controls and groundwater pump
and treat implemented.
Active RCRA Corrective Action Complete. Unit
a part of Multi-Sites Final Decision issued July
15, 1998. Selected remedy is institutional
controls for soils with groundwater pump and
treat. CMI workplan approved by MDNR
November 6, 2000. Remedy implemented
and ongoing. No further regulatory approval
required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 41
Department 20
Degreaser Pit
Located in the southeast quadrant of the Main
Manufacturing Building. Was formerly used to
clean parts using a vapor degreaser which was
known to have leaked. The degreaser has
been removed and the pit filled with sand and
capped with concrete. Institutional controls
and groundwater pump and treat
implemented.
Active RCRA Corrective Action Complete. Unit
a part of Multi-Sites Final Decision issued July
15, 1998. Selected remedy is institutional
controls for soils with groundwater pump and
treat. CMI workplan approved by MDNR
November 6, 2000. Remedy implemented and
ongoing. No further regulatory approval
required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 42
95th Terrace
Site is located under and around street called
95th Terrace on the south side of the
complex. It includes PCB contamination
Active RCRA Corrective Action Complete. Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Access and Deed Restrictions
Exhibit 2, Page 15 of 15
Solid Waste
Management
Unit (SWMU) #
REMEDIAL ACTIONS COMPLETED CURRENT STATUS STATUS ONGOING
originally investigated under the Old 002
Outfall (Abandoned Indian Creek Outfall –
SWMU 14) RFI. Institutional controls,
engineering controls, groundwater pump and
treat, and monitoring implemented.
Final Remedy incorporated into MHWMF
permit revision dated 9/29/06
on land owned by NNSA. Continued
monitoring.
SWMU 43
Test Cell Tanks
Located near the northeast corner of Main
Manufacturing Building. Tanks contained
petroleum hydrocarbons and reported closed.
Institutional and engineering controls and
groundwater pump and treat implemented.
Remediation completed in FY 98. CMI
workplan approved by MDNR November 6,
2000. Remedy implemented and ongoing. No
further regulatory approval required.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Continued groundwater
monitoring and pump and treat. Access and
Deed Restrictions.
SWMU 44
Building 50
Located just east of the West Boilerhouse.
Previous groundwater sampling in vicinity
detected volatile organic compounds. Six
underground tanks and piping removed and
backfilled. Asphalt topping applied. Added to
the 2012 modified Missouri Hazardous Waste
Management Facility Permit
Revised Phase I RFI approved 6/18/15. Should
building footing tile drains be removed,
additional plans for remediation must be
submitted. Any new findings from CP Stage II
related to PCBs in storm sewers should be
provided to DNR.
Continued Institutional and Engineering
Controls as defined in Sitewide Institutional
Controls Plan. Access and Deed Restrictions
on land owned by NNSA. Continued
monitoring.
Exhibit 3
Land Use Restriction Notices for the Underground Tank Farm, North Lagoon and South Lagoon May 1989
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