Sunflower FOSET

[Lenny Siegel <lsiegel@cpeo.org>]

SUNFLOWER FOSET LEAVES OUT ESSENTIAL INFORMATION


The Finding of Suitability for Early Transfer (FOSET) for the Sunflower
Army Ammunition Plant, in Johnson County, Kansas makes a mockery of the
public participation provisions of the early transfer law. Released by
the Army last week, the Sunflower FOSET leaves out information that any
member of the public would require to constructively comment on the
proposed transfer.

As anticipated, the FOSET says, "the ongoing environmental investigation
and remediation of hazardous substances on the property after the
transfer will be accomplished by ... Oz Entertainment Company (OEC),"
which plans to develop a theme park over much of the Plant's 9,000-plus
acres. However, nothing in the FOSET attests to the capability or
financial capacity of Oz Entertainment to complete the cleanup - a
necessity for any early transfer where the transferee assumes
responsibility for remediation. For many months state and federal
agencies have said that they, Oz, and private insurance companies are
working on agreements establishing Oz's responsibility. But the public
has not had the opportunity to see any such documents.

Many times the FOSET refers to a "proposed Consent Order between KDHE
[Kansas Department of Health and Environment] and Oz Entertainment
Company (OEC), which has not been completed or agreed to by the
respective parties  It is anticipated that the Consent Order between
KDHE and Oz Entertainment Company (OEC) will be obtained and provided as
a separate enclosure to or along with this FOSET prior to the Final
FOSET being signed and submitted to the Governor for approval." That is,
the FOSET contains no description of the cleanup standards or strategies
Oz will be required to follow if it takes control of the property. This
consent order is not an ancillary document. It's the heart of the issue
- the official cleanup plan. Without the opportunity to review the
cleanup plan, members local community have no way to determine whether
the early transfer will expose them or theme park visitors and workers
to unacceptably high levels of toxic contamination.

The health and environmental risks at Sunflower aren't just an abstract
possibility. Even before redevelopment and public access were proposed,
Sunflower's high level of contamination qualified the facility for the
"Superfund" National Priorities List, but regulators deferred the
listing. Instead, cleanup is proceeding under the Resource Conservation
and Recovery Act (RCRA). According to the FOSET:

"There are Fifty-Two (52) Solid Waste Management Units (SWMUs) currently
identified in the 1993 RCRA Facility Investigation (RFI) at SFAAP.  Two
(2) additional SWMUs have been identified since the 1993 RFI.  Two (2)
SWMUs have been remediated.  This leaves a total of Fifty-two (52)
active SWMUs currently at SFAAP.  The current status of the Fifty-two
(52) SWMUs to date show, 11 SWMUs requiring additional sampling to fill
data gaps prior to remedy selection; 6 SWMUs which can proceed to
closure documentation for No Further Action (NFA); 33 SWMUs that require
remedial design and remedial action; and 2 SWMUs that require Long Term
Monitoring (LTM). 

The Fifty-two SWMUs different site types include: 

5  Landfills
4  Lagoons
6  Ponds
6  Disposal Areas
5  Ditches
10 Production Areas
16 Miscellaneous"

A FOSET enclosure describing each of the SWMUs not only makes it clear
that the FOSET documents don't have the answers, but that the Army and
its regulators are in the early stages of the remediation process for a
good portion of the property.  Most of the descriptions were developed
before the Army's closure decision, on the assumption that the property
would remain in industrial use. Without a clear idea what is required to
clean up the plant, it is difficult, if not impossible, for those
affected most to evaluate the proposal to turn the plant and the cleanup
program over to Oz.

Here are excerpts from the descriptions of five SWMUs, from that
enclosure. They illustrate both the seriousness of the contamination and
the need for additional study.

B POND AND SLUDGE DISPOSAL AREA

The Draft RFI report indicates that manganese in the groundwater is
associated with noncarcinogenic risk due to potential residential
exposure.  There is the potential for carcinogenic risk due to
nitroglycerin in groundwater.  The groundwater at the site is not
currently used as a drinking water source and is unlikely to be used as
such in the future; therefor, no remedial action for groundwater is
recommended.  The risk assessment indicated that beryllium in the sludge
poses cumulative carcinogenic risk to commercial/industrial workers. 

The risk assessment indicated that potential risk exists through
exposure to Kill Creek surface water by recreational receptors. 
Dieldrin is the primary contributor due to ingestion of fish. It is
recommended that the ponds be closed.


OLD/NEW SANITARY LANDFILLS 

The Draft RFI report states that the primary concerns at SWMUs 18/19 are
the constituents detected in groundwater (sulfide;
is-1,3-dichloropropane, ammonia nitrogen) and dioxins/furans in the
shallow soil.  The risk assessment indicates that the contaminated
groundwater at the site poses potential carcinogenic and noncarcinogenic
risks to residential receptors through ingestion of groundwater and
inhalation of organic constituents from groundwater.  Institutional
controls to provide an access restriction to the site and a groundwater
monitoring program to determine the need for future action is
recommended. 


CONTAMINATED MATERIALS BURNING GROUND

Burning Ground consists of approximately four acres located in the west
central portion of SFAAP.  The site has been in use since 1943 to
decontaminate scrap metal and to burn other combustible material that
has been contaminated with explosives or propellants.  Prior to 1970,
burning of contaminated materials occurred in two open trenches which
were approximately 15 feet deep.  However, in about 1970, two unlined 30
x 300-foot pads were installed where the trenches were located.  The
pads are separated by an earth berm and are still in use.  Contaminated
material accumulates at the site until the pad is full, which generally
takes approximately one to two months.  Burning is initiated using
diesel fuel, waste oils, and scrap wood (including telephone poles). 
After a burn, metal items are collected for salvage.  SFAAP randomly
samples the remainder of the residue for EP toxicity metals, and upon
negative results disposes the ash in the sanitary landfill.  After one
pad is burned, the other pad begins receiving materials for the next
burn.  During a site visit in 1990, burn areas were observed away from
the main burn pads.

Also located on the site is an open top tank, approximately eight feet
in diameter, which was used to burn waste solvent.  Adjacent to the tank
is an elevated platform which appeared to have been used as an unloading
dock for liquids to be emptied into the tank.  At the time of a 1992
site visit the tank appeared to contain water .

Ground-water and surface water runoff from the burn area flow northwest
to Captain Creek or the adjacent Oxbow Lake.

Waste Generated - Combustibles, solvents, explosive and propellant
residues, and metals were handled at this location.

...The draft RFI report recommends further sampling to better define
extent of contamination..


PASTE AREA HALF TANKS AND SETTLING PONDS

According to the Survey, the lagoons were abandoned and in disrepair. 
As a result, unidentified quantities of NC [nitrocellulose] and NG
[nitroglycerin] were known to be in and around the lagoons.  Drilling
was not recommended in the area because lagoon sediment samples were
demonstrated to constitute a reactivity/ignitability hazard in analysis
at the SFAAP laboratory.

Reportedly, overflowing of the metal flumes and half tanks most likely
occurred.  There was no secondary containment.

Due to overgrowth, the location of the remaining Half Tanks and of the
Ponds is not clear.

Waste Generated - The material collected in the Half Tanks consisted of
partially colloided and colloided propellant solids containing lead
salts.  Releases to the Settling Pond included lead salts, NC, NG and
uncolloided propellant.  The pond sediments were also thought to contain
plasticizer (2-NPDA), wax and possibly some carbon black.  The
propellant N5 is a colloided form of the paste. 

Recommendations from Draft RFI Report - None to date.


CALCIUM CARBIDE DISPOSAL AREA

An evaporation pond was reported to be located in the southwest portion
of the landfill.  White and black stains were observed along the edges
of the pond during site visits in 1989 and 1990. 

There is some concern that the surface water runoff from this site
drains to Pyott's Pond via the South Acid Area Drainage Ditch discussed
in the previous section .

Waste Generated - The calcium cyanamide landfilled at this site may
contain calcium carbonate, calcium cyanamide, ammonium, nitrate,
sulfate, guanidine nitrate (GN), and metals.  Byproducts which can be
expected are carbide, cyanide, ammonia, and nitrates.  

Recommendations from Draft RFI Report - The draft RFI report recommends
further investigation to assess the potential for off-site migration of
contaminants.  

-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org
http://www.cpeo.org