NASA NTRS2022
This Interim Measure (IM) Report for Location of Concern (LOC) 2D and LOC 2E summarizes the activities associated with implementation of an IM to address soil and concrete contamination at the Kennedy Space Center (KSC) Headquarters Building Area (KHQA) located at KSC, Florida. KHQA has been designated Solid Waste Management Unit (SWMU) 104 under KSC’s Resource Conservation and Recovery Act Corrective Action Program. The IM consisted of excavating/removing residual polychlorinated biphenyl (PCB) contamination in soil and concrete from two separate areas, LOC 2D and LOC 2E, which were associated with electrical transformer locations. IM activities were conducted in accordance with the Interim Measure Work Plan (IMWP), Revision 1, for KHQA dated June 2018, which was approved by the Florida Department of Environmental Protection in a correspondence letter dated April 2016 and the United States Environmental Protection Agency in a correspondence letter dated August 2018. The objective of the IM was to remove all remaining contaminated media with total PCB concentrations greater than the State of Florida Residential Soil Cleanup Target Level (RSCTL) (0.5 milligrams per kilogram [mg/kg]). This cleanup goal meets unrestrictive re-use conditions in Florida, and is below federal regulations for PCB Bulk Remediation Waste Cleanup of 1 mg/kg for high occupancy, unrestricted use areas, as outlined in 40 Code of Federal Regulations (CFR) 761.61(a). The timeline of the IM was coordinated with demolition of the former KSC Headquarters Building (demolished in 2021) in order to safely remove contaminated media after electrical equipment was de-energized and removed from the site. Excavation activities were conducted between January 10, 2022, and February 8, 2022, and included two waste streams for off-site disposal: (1) PCB-remediation waste greater than or equal to 50 mg/kg, and (2) PCB-remediation waste less than 50 mg/kg. A total of approximately 347 cubic yards (478 tons) of PCB-contaminated soil and concrete was initially removed from the LOC 2D and LOC 2E areas, as defined in the IMWP. An additional 4.35 tons of soil and concrete were removed based on verification sampling, which was conducted until the cleanup goal was achieved. The total area of excavation from both LOC 2D and LOC 2E was approximately 5,186 square feet (0.12 acres), and excavation depths ranged from 0.5 to 4.0 feet below land surface Excavated soils and concrete were stockpiled based on waste stream and subsequently transported and disposed of at Waste Connections of Osceola County, LLC – JED Landfill in St. Cloud, Florida (PCBs less than 50 mg/kg) or the Chemical Waste Management Landfill in Emelle, Alabama (PCBs greater than or equal to 50 mg/kg). Following excavation, clean backfill was brought to the site and provided to the Demolition Contractor to complete backfill and grading in conjunction with their final site restoration activities from building demolition. Post-IM groundwater sampling was conducted in May 2022 at three monitoring wells installed in April 2022 to confirm that PCBs did not leach into groundwater. These wells were installed where the highest PCB concentrations were detected at LOC 2D, LOC 2E, and from the Building Perimeter IM (previously completed in 2020). All PCB results in groundwater were non-detect. Volatile organic compounds were also analyzed based on potential past use of solvents in transformers with PCB-dielectric fluids and the potential release of dielectric fluids containing volatile organic compounds, and all results were non-detect. Based on completion of a successful IM at LOC 2D and LOC 2E, as well as previous remedial actions that have addressed other contamination at KHQA (SWMU 104), No Further Action without controls will be recommended for SWMU 104. NASA will submit separate Site Rehabilitation Completion Order request documentation for SWMU 104 to support an NFA without controls recommendation.