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Air Sparge Pilot Study in the DNAPL Source Zone at Launch Complex 34
Multiple releases of trichloroethene (TCE) occurred at Launch Complex 34 (LC34) between the late 1950s and 1968. A 2007 conceptual site model estimated a 2-acre dense non-aqueous phase liquid (DNAPL) source area with mass in excess of 90,000 pounds, nearly 40 years after termination of launch activities. Located on a barrier island, LC34 currently has no complete exposure pathways and a historical groundwater flow radial from the DNAPL source zone (DSZ), the focus area of this study. The geology at LC34 is classified as Layers 1 through 9 with each layer representing a different lithology. These lithologies contribute to large variations in hydraulic conductivity (1x10-3 cm/sec to 1x10-8 cm/sec) with notable fine-grained units at Layer 4 (sandy clay) and Layer 7 (fine silty sand). Historically, technologies implemented at LC34 have been split vertically based on technology limitations and lithology. Remedial technologies have been evaluated to control and/or remediate the DSZ in the past; however, more aggressive technologies required significant cost and would likely leave considerable mass. Thus, an adaptive site management strategy has been implemented that adopts a treatment train approach which began in 2009 with hydraulic containment via pump and treat to control mass discharge from the DSZ while removing mass as a secondary benefit. Concurrently, hot spot areas in the larger dissolved plume are being treated by air sparging to reduce overall mass and the plume footprint. In 2019, a re-characterization of the DSZ was completed to update conditions in support of implementing more aggressive technologies as part of the treatment train approach. The results showed that the DSZ remained relatively the same size but with a slightly different morphology. Moreover, data showed that the fine-grained units (Layers 4 and 7) are storing most of the remaining mass, with TCE concentrations suggestive of DNAPL extending into Layer 7 (approximately 80 to 100 ft below land surface). Based on the current conditions, more aggressive technologies are still cost prohibitive; therefore, a different approach is warranted to determine the next implementable step in the treatment train. Air sparging is being proposed as a technology alternative based on several factors including lower treatment costs. A pilot study was conducted to test the feasibility of air sparging in the DSZ as the next step in the treatment train for that area.
Launch Complex 34, SWMU Cc054 2021 DNAPL Source Zone Operations, Maintenance, and Monitoring, and Hot Spot 6 Air Sparge System Annual Performance Monitoring Report Cape Canaveral Space Force Station, Florida
This Annual Performance Monitoring Report (PMR) for the Dense Non-Aqueous Phase Liquid (DNAPL) Source Zone (DSZ) and Hot Spot 6 (HS 6) Air Sparge (AS) System presents the results of Year 12 operation of the hydraulic containment (HC) Interim Measure (IM), the results of performance monitoring direct-push technology (DPT) sampling and monitoring well sampling conducted in the DSZ, and the results of operations and performance sampling of the HS 6 AS IM at Launch Complex 34 (LC34), located at Cape Canaveral Space Force Station (CCSFS), Florida. Site-wide biennial LTM sampling was not conducted during this reporting period and is scheduled to be conducted in December 2022. The timeframe for activities documented in this PMR extends from April 1, 2021 to March 31, 2022. LC34 has been designated Solid Waste Management Unit CC054 under the Kennedy Space Center (KSC) Resource Conservation and Recovery Act Corrective Action Program. The objective of the HC IM at LC34 is to contain the DSZ and deep dissolved-phase trichloroethene (TCE) high concentration plume via operation of a hydraulic containment system (HCS). The pre-IM design 300 micrograms per liter (μg/L) TCE groundwater contour was used to establish the deep zone capture area for deep recovery wells, and the shallow zone capture area was defined by the DSZ. The system began operating in 2010, and in 2015, the system was expanded to provide HC for areas within the 300 μg/L TCE groundwater isocontours of HS 3 and 4. In 2018 and 2019, an investigation was conducted to re-characterize the DSZ, which included investigating TCE mass in Layer 7. This data was subsequently used to optimize the pumping rates of the HCS to more adequately capture residual contaminant mass. The operational period for Year 12 of the HCS was from April 1, 2021 to March 31, 2022. Operational runtime for the system was 94 percent during Year 12, with downtime events attributed to planned maintenance, system repairs, and power outages. As of March 31, 2022, a total of 285,712,801 gallons of groundwater containing 84,933 pounds of VOCs have been removed by the HCS. Influent concentrations of TCE have decreased since startup from approximately 280,000 µg/L (January 2010) to 12,000 µg/L (March 2022). During the reporting period, all effluent concentrations from the HCS (aqueous and vapor) were below regulatory reporting limits, indicating the system continues to operate as intended. Performance monitoring was conducted in December 2021 within the DSZ to evaluate TCE contamination. Groundwater samples were collected via DPT at nine locations, consistent with previous events in 2017, 2018, 2019, and 2020. Full vertical profile sampling was completed at each DPT from 8 to 98 ft bls, at 5 foot intervals. The DPT performance monitoring results are summarized in this PMR. The results revealed TCE remains at concentrations greater than 11,000 µg/L in the DSZ (1-percent solubility, indicative of DNAPL) at eight of the nine DPT locations at depths ranging from 8 to 98 ft bls. An overall increasing trend of TCE concentrations was observed in DPT samples during this reporting period, which may be due to several recovery wells that were turned off during the AS Pilot Study in the DSZ that operated from July 2021 to February 2022 (documented separately from this report). The maximum TCE concentration in 2021 was 15,400,000 µg/L in the 58 ft bls depth interval at DPT597 (previous maximum result in 2020 was 1,690,000 at 48 ft bls at DPT596). During the 2021 DPT event, the overall majority of TCE contamination was identified in the 58 ft bls interval (below Layer 4), where in the previous year the majority of mass was observed in Layer 4. This trend appears to indicate continued mass discharge from Layer 4 (fine-grained unit). In addition to DPT sampling, monitoring well samples were collected from deep wells in the DSZ area (Layers 7 and 8) to verify vertical delineation. All monitoring well results were non-detect or below cleanup levels, with exception of one well (IW0162, screened 105 to 115 ft bls, which is below the existing recovery well capture zone) where TCE was identified above cleanup target levels. The HS 6 AS system remained operational during the reporting period covered under this report. The HS 6 AS IM was initiated in 2018 with 160 AS wells, and expanded in 2019 with an additional 140 AS wells. Quarterly performance monitoring was reduced to semi-annual prior to this operational period. The results of the HS 6 system operation and semi-annual performance monitoring are summarized in this report. Semi-annual monitoring results collected in April and October 2021 show concentrations of contaminants of concern (cis-1,2-dichloroethene, trans-1,2- dichloroethene, and vinyl chloride) are generally decreasing and not impacting the surface water drainage canal, indicating the HS 6 IM is meeting objectives. Overall, the tasks associated with Year 12 operation of the HC IM and operation of the HS 6 AS IM were performed in accordance with the recommendations of the 2020 LC34 (Year 11) Operations, Maintenance, and Monitoring Report for DNAPL Source Zone, Site Wide LongTerm Monitoring, and Hot Spot 6 Air Sparging System PMR (NASA, 2021c). Evaluation of results from the HC IM and HS 6 IM show that these systems are operating as designed and meeting performance objectives.
Launch Complex 34, SWMU CC054 2023 DNAPL Source Zone Operations, Maintenance, and Monitoring, Site-Wide Long-Term Monitoring, and Hot Spot 6 Air Sparge System Annual Performance Monitoring and Phase Two Expansion Construction Completion Report Cape Canaveral Space Force Station, Florida
This Annual Performance Monitoring Report (PMR) for the Dense Non-Aqueous Phase Liquid (DNAPL) Source Zone (DSZ), Site-Wide Long-Term Monitoring (LTM), and Hot Spot 6 (HS 6) Air Sparge (AS) System presents the results of Year 14 operations and performance monitoring of the hydraulic containment (HC) Interim Measure (IM), details associated with construction and implementation of the HS 6 AS system expansion (Phase Two), and the results of operations and performance sampling of the HS 6 AS IM at Launch Complex 34 (LC34), located at Cape Canaveral Space Force Station (CCSFS), Florida. The timeframe for activities documented in this PMR extends from April 1, 2023 to March 31, 2024. LC34 has been designated Solid Waste Management Unit CC054 under the Kennedy Space Center (KSC) Resource Conservation and Recovery Act Corrective Action Program. The objective of the HC IM at LC34 is to contain the shallow and deep DSZ and surrounding dissolved-phase trichloroethene (TCE) high concentration plume via operation of a hydraulic containment system (HCS). The pre-IM design 300 micrograms per liter (μg/L) TCE groundwater contour was used to establish the deep zone capture area for deep recovery wells, and the shallow zone capture area was defined by the DSZ. The system began operating in 2010, and in 2015, the system was expanded to provide HC for areas within the 300 μg/L TCE groundwater isocontours of HS 3 and 4. In 2018 and 2019, an investigation was conducted to recharacterize the DSZ, which included investigating TCE mass in Layer 7. This data was subsequently used to optimize the pumping rates of the HCS and install additional recovery wells in Layer 7 to more adequately capture residual contaminant mass. The operational period for Year 14 of the HCS was from April 1, 2023 to March 31, 2024. Operational runtime for the system was 94 percent during Year 14, with downtime events attributed to planned maintenance, system repairs, and power outages. As of March 31, 2024, a total of 344,849,634 cumulative gallons of groundwater containing 94,656 pounds of chlorinated volatile organic compounds (CVOCs) have been removed by the HCS. During the reporting period covered under this report, the HCS recovered 31,176,393 gallons and approximately 6,319 pounds of CVOC mass. Total combined influent concentrations of TCE have decreased since startup from approximately 280,000 µg/L (January 2010) to 25,000 µg/L (March 2024). During the reporting period, all effluent concentrations from the HCS (aqueous and vapor) were below regulatory reporting limits, indicating the system continues to operate as intended. Performance monitoring was conducted in January 2024 within the DSZ to evaluate TCE contamination. Groundwater samples were collected via DPT at nine locations, consistent with previous events between 2017 and 2022. Full vertical profile sampling was completed at each DPT from 8 to 98 feet below land surface (bls), at 5-foot intervals. The DPT performance monitoring results are summarized in this PMR. The results revealed TCE remains at concentrations greater than 11,000 µg/L in the DSZ (1-percent solubility, indicative of DNAPL) at eight of the nine DPT locations and at depths ranging from 28 to 98 feet bls. An overall decreasing trend of TCE concentrations was observed in DPT samples during this reporting period, which is a reduction from the previous event (December 2022) and the peak event in December 2021, where TCE percentages appeared to increase in all depth zones because several recovery wells were turned off during the AS pilot study in the DSZ. The maximum TCE concentration in January 2024 was 1,600,000 µg/L in the 53 feet bls depth interval at DPT594 (previous maximum result in 2022 was 1,800,000 µg/L in the 48 feet bls depth interval at DPT599). This maximum concentration in the 53 feet bls depth interval is in the deep capture zone. During the January 2024 DPT event, the largest portion of TCE mass was observed in the 48 feet bls interval above/within Layer 4. This trend remains consistent with previous years and appears to indicate continued mass discharge from Layer 4 (fine-grained unit). In addition to DPT sampling, annual groundwater samples were collected from 11 deep monitoring wells in the DSZ area (Layers 7 and 8) in December 2023 to verify vertical and horizontal delineation. Three of the wells were also sampled biweekly to evaluate operations of recovery well RW21D (screened 86 to 106 feet bls), which was installed in January 2023. Of the Layer 7/8 monitoring sampled only annually, results were non-detect or less than groundwater cleanup target levels GCTLs in December 2023, with the exception of one well, IW45D2, which had a cis-1,2-dichloroethene (cDCE), detection greater than the GCTL. Of the three wells sampled biweekly during the operational period, the well located closest to Layer 7 recovery well RW21D (IW44D2, screened 105 to 115 feet bls) had concentrations of TCE, cDCE and vinyl chloride (VC) greater than GCTLs throughout the operational period, but displayed a decreasing trend since the peak concentrations in September 2023. The maximum TCE concentration during this operational period was 190,000 µg/L at IW44D2 in September 2023, but reduced to 700 µg/L in March 2024, indicating the HCS is still effectively removing mass from the source area. Expansion of the HCS and addition of new recovery wells is ongoing and will continue to be evaluated as the groundwater recovery scheme is optimized. Details of the expansion and optimization will be provided in a future PMR. The HS 6 AS IM was initiated in 2018 with 160 AS wells and expanded in 2019 with another 140 AS wells. An additional expansion of the HS 6 AS IM was completed during the reporting period covered under this report and details of the construction implementation and startup of the expansion are detailed in Section III of this report. The new expansion, referred to as Phase Two, was implemented between August 17, 2022 and August 28, 2023, and included the installation of 190 air sparge wells to treat an additional 11.2 acres. The original configuration (referred to as Phase One) operated until Phase Two came online, then all but 52 AS wells were turned off so the components could be moved and utilized in the Phase Two area. The 52 AS wells that remain on are in a barrier configuration preventing contaminated groundwater from impacting the treated area. The HS 6 AS system (both Phase One and Two) operated normally during the reporting period covered under this report. Semi-annual performance monitoring of the Phase One configuration was conducted in April and November 2023, consistent with previous years. For the Phase Two configuration, 21 new monitoring wells were installed and sampled quarterly, with a baseline event in July 2023, and quarterly events in November 2023 and February 2024 summarized in this report. Semi-annual monitoring results collected in April and October 2023 show concentrations of contaminants of concern (cDCE, trans-1,2-dichloroethene, and VC) have decreased to less than GCTLs in nearly all wells and not impacting the surface water drainage canal, indicating the HS 6 IM continues to meet objectives. The baseline and quarterly sampling for the Phase Two configuration indicate generally decreasing concentrations in wells within and around the perimeter of the treatment area. At least two more quarters of monitoring will be conducted and once those results are evaluated a reduced the sampling frequency may be considered. Overall, the tasks associated with Year 14 operation of the HC IM and operation of the HS 6 AS IM were performed in accordance with recommendations included in the previous 2022 LC34 (Year 13) PMR. Evaluation of results from the HC IM and HS 6 IM show that these systems are operating as designed and meeting performance objectives.
Launch Complex 34, SWMU CCO542022 DNAPL Source Zone Operations, Maintenance, and Monitoring, Site-Wide Long-Term Monitoring, and Hot Spot 6 Air Sparge System Annual Performance Monitoring Report Cape Canaveral Space Force Station, Florida
This Annual Performance Monitoring Report (PMR) for the Dense Non-Aqueous Phase Liquid (DNAPL) Source Zone (DSZ), Site-Wide Long-Term Monitoring (LTM), and Hot Spot (HS) 6 Air Sparge (AS) System presents the results of Year 13 operation of the hydraulic containment (HC) Interim Measure (IM), the results of performance monitoring direct-push technology (DPT) sampling and monitoring well sampling conducted in the DSZ, results of the biennial site-wide LTM event, and the results of operations and performance sampling of the HS 6 AS IM at Launch Complex 34 (LC34), located at Cape Canaveral Space Force Station (CCSFS), Florida. This site has been designated Solid Waste Management Unit (SWMU) CC054 under the Kennedy Space Center (KSC) Resource Conservation and Recovery Act (RCRA) Corrective Action Program. For the site-wide biennial LTM event, a total of 55 monitoring wells were sampled for volatile organic compounds (VOCs) in February 2023 and one well was sampled for polychlorinated biphenyls (PCBs) in December 2022. One well planned for VOC sampling was found to be destroyed and could not be sampled (CW0002). The LTM wells are screened in two lithologic zones: Layer 1 (0 to 25 feet below land surface [bls]) and Layer 2 (25 to 30 ft bls), and are located in the outlying areas of LC34 to monitor groundwater conditions within the Low-Concentration Plume (LCP), defined as concentrations exceeding Groundwater Cleanup Target Levels (GCTLs), and the High-Concentration Plume (HCP), defined as concentrations exceeding Natural Attenuation Default Concentrations (NADCs). Results from the biennial sampling event indicated overall plume stability and delineation for the plume, which extends over 300 acres. The operational period for Year 13 of the HCS was from April 1, 2022 to March 31, 2023. Operational runtime for the system was 90 percent during Year 13, with downtime events attributed to planned maintenance, system repairs, and power outages. As of March 31, 2023, a total of 313,673,241 cumulative gallons of groundwater containing 88,337 pounds of VOCs have been removed by the HCS. Influent concentrations of trichloroethene (TCE) have decreased since startup from approximately 280,000 μg/L (January 2010) to 12,000 μg/L (March 2023). During the reporting period, all effluent concentrations from the HCS (aqueous and vapor) were below regulatory reporting limits, indicating the system continues to operate as intended. Performance monitoring was conducted in December 2022 within the DSZ to evaluate TCE contamination. Groundwater samples were collected via DPT at nine locations, consistent with previous events between 2017 and 2021. Full vertical profile sampling was completed at each DPT from 8 to 98 feet bls, at 5-foot intervals. The DPT performance monitoring results are summarized in this PMR. The results revealed TCE remains at concentrations greater than 11,000 μg/L in the DSZ (1-percent solubility, indicative of DNAPL) at eight of the nine DPT locations and at depths ranging from 8 to 98 feet bls. In addition to DPT sampling, groundwater samples were collected from deep monitoring wells in the DSZ area (Layers 7 and 8) in December 2022 to verify vertical delineation. Layer 7/8 monitoring well results were non-detect in December 2022, with exception of three wells (IW0162, IW043D2, and IW044D2), where TCE, cis-1,2-dichloroethene (cDCE), and/or vinyl chloride (VC) were detected above GCTLs. These wells are screened 105 to 115 feet bls, which is below the existing recovery well capture zone. TCE was first detected in IW0162 in December 2021 and has since been sampled at least monthly to monitor TCE concentrations. The maximum TCE concentration during this operational period was 15,000 μg/L at IW0162 in March 2023. Because of the increased TCE concentrations in this well, a new recovery well (RW21D), screened 86 to 106 feet bls, was installed in January 2023 and incorporated into existing HCS operations. The HS 6 AS IM was initiated in 2018 with 160 AS wells, and expanded in 2019 with an additional 140 AS wells. Quarterly performance monitoring was reduced to semi-annual in 2020. The HS 6 AS system remained operational during the reporting period covered under this report. The results of the HS 6 system operation and semi-annual performance monitoring are summarized in this report. Semi-annual monitoring results collected in April and October 2022 show concentrations of contaminants of concern (cDCE, trans-1,2-dichloroethene, and vinyl chloride) are generally decreasing and not impacting the surface water drainage canal, indicating the HS 6 IM is meeting objectives. A Phase Two Expansion of the HS 6 AS IM was recently completed. As of the date of this report, the expansion became operational in August 2023 and the first quarter of monitoring was conducted in November 2023. Details of the construction, start-up, and performance monitoring will be included in a future Annual PMR. Overall, the tasks associated with Year 13 operation of the HC IM, operation of the HS 6 AS IM, and biennial site-wide sampling were performed in accordance with recommendations included in the previous 2021 LC34 (Year 12) annual report. Evaluation of results from the HC IM and HS 6 IM show that these systems are operating as designed and meeting performance objectives. Results from the site-wide biennial LTM program also show that the overall network of monitoring wells is adequate to continue monitoring plume-wide conditions.
Launch Complex 34 SWMU CC054 Hot Spot Area 6 Expansion - Phase Three Implementation Work Plan
This Hot Spot (HS) Area 6 Air Sparge Expansion – Phase Three Implementation Work Plan (IWP) was prepared by Tetra Tech, Inc., for the National Aeronautics and Space Administration (NASA) under the Indefinite Delivery Indefinite Quantity Contract 80KSC019D0011-80KSC019F0067, for the implementation of an Air Sparging (AS) Interim Measure (IM) at Launch Complex 34 (LC34), located at Cape Canaveral Space Force Station (CCSFS), Florida. LC34 has been designated as Solid Waste Management Unit (SWMU) CC054 under the Kennedy Space Center (KSC) Resource Conservation and Recovery Act (RCRA) operating permit. Expansion of the HS 6 IM will include installation of an additional 192 AS wells to depths of approximately 40 feet below land surface (bls) to remediate contaminated groundwater within two areas located west and northeast of the existing HS 6 AS treatment area. These areas were delineated via direct push technology investigations in September and October 2023. The expansion will target “hot spot” concentrations of cis-1,2-dichloroethene (cDCE) and vinyl chloride (VC), which are the contaminants of concern in these areas with concentrations greater than 10-times Florida Department of Environmental Protection Natural Attenuation Default Concentrations. The highest cDCE and VC concentrations detected in the proposed phase three expansion area were 58,000 micrograms per liter (μg/L) (32 to 36 feet bls) and 12,000 μg/L (23 to 27 feet bls), respectively. The objective for this expansion is to remediate contaminated groundwater within the treatment zone to support transition to long-term monitoring. This phase three expansion will add an additional 9.4 acres of treatment area to the HS 6 IM, which currently covers approximately 26.9 acres.
Field demonstration of DNAPL dehalogenation using emulsified zero-valent iron
This paper describes the results of the first field-scale demonstration conducted to evaluate the performance of nanoscale emulsified zero-valent iron (EZVI) injected into the saturated zone to enhance in situ dehalogenation of dense, nonaqueous phase liquids (DNAPLs) containing trichloroethene (TCE). EZVI is an innovative and emerging remediation technology. EZVI is a surfactant-stabilized, biodegradable emulsion that forms emulsion droplets consisting of an oil-liquid membrane surrounding zero-valent iron (ZVI) particles in water. EZVI was injected over a five day period into eight wells in a demonstration test area within a larger DNAPL source area at NASA's Launch Complex 34 (LC34) using a pressure pulse injection method. Soil and groundwater samples were collected before and after treatment and analyzed for volatile organic compounds (VOCs) to evaluate the changes in VOC mass, concentration and mass flux. Significant reductions in TCE soil concentrations (>80%) were observed at four of the six soil sampling locations within 90 days of EZVI injection. Somewhat lower reductions were observed at the other two soil sampling locations where visual observations suggest that most of the EZVI migrated up above the target treatment depth. Significant reductions in TCE groundwater concentrations (57 to 100%) were observed at all depths targeted with EZVI. Groundwater samples from the treatment area also showed significant increases in the concentrations of cis-1,2-dichloroethene (cDCE), vinyl chloride (VC) and ethene. The decrease in concentrations of TCE in soil and groundwater samples following treatment with EZVI is believed to be due to abiotic degradation associated with the ZVI as well as biodegradation enhanced by the presence of the oil and surfactant in the EZVI emulsion.
Field Demonstration of DNAPL Dehalogenation Using Emulsified Zero-Valent Iron
This paper describes the results of the first field-scale demonstration conducted to evaluate the performance of nano-scale emulsified zero-valent iron (EZVI) injected into the saturated zone to enhance in situ dehalogenation of dense, non-aqueous phase liquids (DNAPLs) containing trichloroethene (TCE). EZVI is an innovative and emerging remediation technology. EZVI is a surfactant-stabilized, biodegradable emulsion that forms emulsion droplets consisting of an oil-liquid membrane surrounding zero-valent iron (ZVI) particles in water. EZVI was injected over a five day period into eight wells in a demonstration test area within a larger DNAPL source area at NASA's Launch Complex 34 (LC34) using a pressure pulse injection method. Soil and groundwater samples were collected before and after treatment and analyzed for volatile organic compounds (V005) to evaluate the changes in VOC mass, concentration and mass flux. Significant reductions in TCE soil concentrations (>80%) were observed at four of the six soil sampling locations within 90 days of EZVI injection. Somewhat lower reductions were observed at the other two soil sampling locations where visual observations suggest that most of the EZVI migrated up above the target treatment depth. Significant reductions in TCE groundwater concentrations (57 to 100%) were observed at all depths targeted with EZVI. Groundwater samples from the treatment area also showed significant increases in the concentrations of cis-1,2-dichloroethene (cDCE), vinyl chloride (VC) and ethene. The decrease in concentrations of TCE in soil and groundwater samples following treatment with EZVI is believed to be due to abiotic degradation associated with the ZVI as well as biodegradation enhanced by the presence of the oil and surfactant in the EZVI emulsion.
Pedestal Hazard Abatement and Soil Removal Construction Completion Report for Launch Complex 34, Solid Waste Management Unit CC054, Cape Canaveral Space Force Station, Florida
This Construction Completion Report summarizes the activities associated with implementation of an interim measure (IM) for hazard abatement of the Launch Pedestal and soil removal at Launch Complex 34 (LC34), Cape Canaveral Space Force Station, Florida. The purpose of the hazard abatement IM was to mitigate any continuing source of contamination associated with residual paint on the Launch Pedestal that contained polychlorinated biphenyls (PCBs). Sampling determined that residual PCB concerns were limited to the steel elements on the top-side of the Pedestal, which included the torus ring, feed pipe, down pipes, pipe straps and shields, remaining steel cover plates and bolts, and railing support steel. The IM also mitigated the potential spread of contamination to surrounding areas by removing fallen metal fragments from the concrete launch pad, as well as soil from trenches on the launch pad where PCB-containing paint chips may have accumulated prior to or during Pedestal hazard abatement activities.