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Documentation of Environmental Indicator Determination

in accordance with EPA Interim Final Guidance 2/5/99

RCRA Corrective Action


Environmental Indicator (EI) RCRA Info code (CA725)

Current Human Exposures Under Control

Facility Name: Cook Composites and Polymers Co.


Facility Address: 920 East 14th Avenue, Kansas City, Missouri
Facility EPA ID #: MOD086787371

1. Has all available relevant/significant information on known and reasonably suspected releases to soil,
groundwater, surface water/sediments, and air, subject to RCRA Corrective Action (e.g., from Solid
Waste Management Units (SWMU), Regulated Units (RU), and Areas of Concern (AOC)), been
considered in this EI determination?

X If yes - check here and continue with #2 below.

_____ If no - re-evaluate existing data, or

_____ if data are not available skip to #6 and enter “IN” (more information needed) status
code.

The Cook Composites and Polymers Company (Cook) facility, located at 920 East 14th Avenue, North
Kansas City, Missouri (see Figures in Appendix A), was established as Cook Paint and Varnish in 1913. In
1927, Cook Paint and Varnish was incorporated in Delaware. The company changed its name to Curran
Paint Corporation in 1979 and became Cook Paint and Varnish Company in 1980. In 1990, Cook
Composites and Polymers, a partnership between Cook Paint and Varnish and the French company Total-
Chimie, assumed ownership of the Cook facility (Jacobs Engineering Group, Inc. [Jacobs] 1992).

The Cook facility is located on 18.5 acres. Facility buildings include manufacturing and operations
buildings, a warehouse, and a research and development (R&D) laboratory (see Figures in Appendix A). A
chain link fence and a guardhouse at the main facility entrance secure the main plant area, which is almost
entirely paved. A parking area, settling basin, and granulated activated charcoal unit are located east of the
main plant area and are not paved or fenced (Jacobs 1992). Adjacent properties include Seeburg Warehouse
and Fabri-Quilt, Inc., facilities to the south; Harrisonville Harness and D&O Distributing facilities to the
west; Dean Rubber Company, Pella Windows and Doors (Warehouse and Service), and Stationers
Distributing Company to the north; and the Burlington Northern Railroad Hub Center and railroad tracks to
the east (Burns & McDonnell Engineering Company, Inc. [BMcD] 2002).

Historical Cook facility manufacturing processes include solvent recovery and production of resin, foam, gel
coatings, and industrial and specialty paint coatings (Jacobs 1992). Current operations include styrene
blending in the former paint factory, some esterification of isophthalic acids, and laboratory research (BMcD
2002). Waste streams produced by the Cook facility include esterification water, special wastes (raw
material bags), waste solvent, dirty styrene, settling basin water, settling basin sludge, used rags, used filters,
still bottoms (reclaimed ethyl acetate from the R&D laboratory), off-specification and expired raw materials,
general trash, bag house dusts, filter press paper from resin operation, granulated activated carbon sludge,
and resin operation solutions (Jacobs 1992).
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In 2001-2002, the facility constructed a new processing building (Building 80). Two older buildings were
torn down from the new building location (Buildings 24 and 57) Throughout the process of the new
construction the subsurface soil was characterized and one new SWMU, SWMU L, and one AOC, AOC-4
PCB Area were identified. Because of the presence of contamination above risk-based levels, a clay barrier
was constructed to separate the new building from the PCB Area, and a vapor barrier was installed in the
concrete foundation. This was done to prevent potential future exposures to future workers. (See Figures in
Appendix A)

The following solid waste management units (SWMU) were identified in a visual site inspection of the Cook
facility conducted by U.S. Environmental Protection Agency (EPA) contractors in 1991 (Jacobs 1992) and in
subsequent inspections and investigations (BMcD 2002). SWMUs A through K were designated as part of
the visual site inspection, and information on these SWMUs was obtained from EPA’s files or Cook’s 1980
Part B Permit Application (Jacobs 1992). The SWMUs are depicted in Figure 2 (Appendix A). All SWMU
descriptions are derived from Environmental Priorities Initiative/Preliminary Assessment (EPI/PA) Report
(Jacobs 1992), as updated by the RCRA Facility Assessment (RFA) Report (MDNR 1996). The exception is
SWMU L, which is derived from the RCRA Facility Investigation (RFI) Work Plan (BMcD 2002).

SWMU Name Status Description


SWMU 1: Baghouse Inactive The 20- by 10-foot, 400-gallon capacity unit was installed on the roof of the
Dust Filter Unit old paint factory in 1977. Until 1990 (during paint production), the unit
filtered the factory air, removing dust containing lead, cadmium, barium,
and other heavy metals. Wastes were removed and disposed of as
hazardous waste one time. After 1990, dust accumulating in the filter
contained talc, clay, and fumed silica from gel-coat operations. Materials
were recycled on site into primers. No release from this SWMU has been
documented. The 1996 RFA reported that SWMU 1 was inactive.
SWMU 2: Wastewater Active The 30,000-gallon, steel-enforced concrete settling basin was constructed in
Treatment Plant Settling 1975. SWMU 2 receives liquid from tank washing, sanitary and storm
Basin sewers, and air pollution scrubbers; wastes include ethylbenzene, toluene,
Active xylene, styrene, and lead. Ethylbenzene and styrene are skimmed from the
top and accumulated for transport to the fuel blending operation. The rest
of the liquid passes through a sand filter and an activated carbon filter into
the North Kansas City Public Owned Treatment Works (POTW). About
8,000 gallons of D008 sludge are removed from the basin twice a year and
disposed of off site. EPA’s 1984 Compliance Evaluation Inspection noted
“evidence of spillage.” Metals and volatile organic compounds (VOC)
have been detected in soils, and metals have been detected in groundwater
at SWMU 2.
SWMU 3: Waste Inactive The 40-foot-square storage area was located in the building that housed the
Solvent/Sludge Storage former solvent reclamation unit. Waste solvents and sludges were blended
Area at Location of in 350-gallon containers and pumped to SWMU 12, an aboveground waste
Former Solvent storage tank. Wastes included ethylbenzene, toluene, xylene, styrene,
Reclamation Unit acrylic and polyester resins, materials skimmed from the wastewater
treatment plant settling basin, and used toluene and methyl ethyl ketone
(MEK). No release from this SWMU has been documented. The 1996
RFA reported that the storage tanks were decommissioned.
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SWMU 4: 90-Day Active Since 1966, the bermed, 20- by 40-foot, concrete structure has stored up to
Hazardous Waste 100 55-gallon drums. SWMU 4 has provided less-than-90-day storage for
Storage Area for Drums wastes–including off-specification coatings, resins, emulsions, alkyds,
microgels, gel-coats, filter bags, and filter press papers. Contaminants of
concern include lead, ethylbenzene, toluene, xylene, and styrene. No
release from this SWMU has been documented.
SWMU 5: R&D Solvent Inactive The solvent reclamation cabinet, pan, and distillation bag were used to
Reclamation Unit reclaim MEK and ethyl acetate for reuse in the R&D facility. Still bottoms
were recovered as a dry cake and burned with blended fuels. Wastes
included ethyl acetate, MEK, and distillation filter cake (F003). No release
from this SWMU has been documented. The 1996 RFA reported that this
unit was decommissioned and removed.
SWMU 6: Nine Parts Inactive Stainless steel parts washers were located on the second, third, fourth, and
Washers in the R&D fifth floors of the R&D building. Each washer had a 10-gallon capacity and
Building generated 5 gallons of contaminated solvent each month. No release from
this SWMU has been documented. The 1996 RFA reported that the parts
washers were removed.
SWMU 7: Three Special Active The roll-off containers, which have been used since the mid- to late- 1980s,
Waste Roll-off previously were located near the north and south boundaries of the fenced
Containers and Special portion of the facility. The compactor, which has been on site since 1990,
Waste Compactor is located outside the old paint factory. Special wastes accumulated in the
roll-off containers included about 10,000 pounds per month of pails, bags,
and cardboard used to package raw materials. The compactor was leased
from Sloss Systems, and the roll-off containers were emptied by Waste
Management. No release from this SWMU has been documented. The
roll-off containers are still in operation but may have been relocated on site.
SWMU 8: Empty Drum Inactive The paved 10- by 20-foot drum storage area was used to store empty drums
Storage Area potentially containing residual solvents. No release from this SWMU has
been documented. The 1996 RFA reported that all drums were removed
from the unit.
SWMU 9: 12,000- Inactive The 12,000-gallon, stainless steel, aboveground storage tank was installed
Gallon Aboveground in 1990. The tank stored esterification waste, which was potentially
Waste Storage Tank hazardous for ignitability. The tank also stored rainwater with high
chemical or biochemical oxygen demand that accumulated in the leaking
basement of the former resin plant. No release from this SWMU has been
documented. The tank is clean, empty, and available as a backup.
SWMU 10: Two 8,000- Active This SWMU originally consisted of two 8,000-gallon, carbon steel storage
Gallon Carbon Steel tanks that were installed between 1966 and 1971. The tanks held
Hazardous Waste wastewater from the esterification process in the resin plant; the
Storage Tanks esterification water was potentially hazardous for ignitability. The tanks
were contained within a concrete structure. No release from this SWMU
was documented (Jacobs 1992). The area was excavated during demolition
of Buildings 24 and 57, and construction of Building 80 in 1991 and 1992
(Burns & McDonnell [BMcD] 2003). Between 1992 and 1996, the tanks
were replaced with new12,000-gallon tanks (MDNR 1996).
SWMU 11: Satellite Inactive The satellite accumulation area was a paved area for staging 8 to 10 drums
Accumulation Area for containing filter press papers, off-specification latex emulsion resins, solids
Resin Plant for fuel blending, and solvent-contaminated wastes (D001, D008, D035,
and F003). The 1996 RFA reported that no drums currently are stored at
this location. No release from this SWMU has been documented.
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SWMU 12: Inactive The 20,000-gallon stainless steel tank was installed prior to 1966 and
Aboveground Waste contained blended solid and liquid wastes from gel-coat operations. The
Storage Tank waste consisted of ethyl acetate, styrene, MEK, xylene, toluene, and lead.
The material was collected by Heritage Environmental Services for use as a
blended fuel off site. The tank was replaced in 1993, and the new tank is
contained by a concrete floor and containment wall. The new tank
currently is used as a backup. No release from this SWMU has been
documented.
SWMU 13: Satellite Inactive This SWMU was operated from 1975 and consisted of a graveled area
Accumulation Area at previously used to store a drum that accumulated ethylbenzene and styrene
Settling Basin skimmed from the settling basin; the drum also accepted sludge from the
granular activated carbon (GAC) filtration unit installed in 1988. Wastes
skimmed from the settling basin were taken to SWMU 12 for fuel blending.
GAC wastes were recycled by Calgon at a rate of about four drums per
year–contaminants included MEK, xylene, ethylbenzene, toluene, and lead.
The 1996 RFA reported that no drums currently are stored at this location.
No release from this SWMU has been documented.
SWMU 14: Temporary Inactive Drums of filters and mud from the flocculation process were accumulated
Storage Area for in this area of the old paint factory. Wastes included lead before plant
Flocculation Solids processes changed. The 1996 RFA reported that the flocculation process
was discontinued, and the storage area closed. No release from this SWMU
has been documented.
SWMU 15: Satellite Active The brick and concrete building on the northwest corner of Knox and 15th
Accumulation Area for Streets is used to accumulate waste oil. Waste oil storage at SWMU 15
Waste Oil began prior to 1966 and is ongoing. No release from this SWMU has been
documented.
SWMU 16: 90-Day Inactive The 75- by 200-foot, prefabricated building with a concrete floor was used
Drum Storage Area to store up to 300 drums of viscous non-pumpable materials such as resins
and pigments. Associated contaminants included corrosives, lead, xylene,
solvents, and off-specification materials. No drums currently are stored in
this area. Prior to use as a drum storage area, this unit was the location of
the foam plant. Associated contaminants included polyols and isocyanates.
No release from this SWMU has been documented.
SWMU 17: Two Paint Inactive Two paint booths were located in the R&D building, as were drums of used
Booths in R&D Building paint filters. Associated wastes included MEK, ethyl acetate, and lead. The
booths have been removed. No release from this SWMU has been
documented.
SWMU 18: Inactive The 2,000-gallon steel tank contained waste solvent, including spent
Aboveground Waste toluene and MEK. The tank was used prior to 1978 and has been cleaned
Storage Tank for Used and emptied for future use. A concrete containment wall currently is in
Solvents place. No release from this SWMU has been documented.
SWMU 19: Satellite Inactive Up to 8 or 10 drums of filter press papers and off-specification latex resins
Accumulation Area for were stored in this accumulation area for the resin plant. Associated
the Resin Plant contaminants included ethylbenzene, MEK, lead, xylene, and toluene. No
drums currently are stored at this location. No release from this SWMU has
been documented.
SWMU 20: Satellite Inactive Drums of lead-containing filters and mud from the flocculation process
Accumulation Area for were accumulated in this area. The 1996 RFA reported that the flocculation
Collection of Water process was discontinued, and the storage area closed. No release from the
Treatment Flocculation SWMU has been documented.
Process Solids
SWMU 21: Two Rag Inactive The covered 55-gallon drums located in the R&D building and resin plant
Accumulation Drums served as accumulation points for solvent-contaminated rags. The 1996
RFA reported that the drums were removed. No release from this SWMU
has been documented.
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SWMU 22: Settling Inactive The settling and skimming basin was constructed in the sanitary sewer
Basin Identified in 1980 system in 1979 or 1980 for pollution control. Discharged wastewater that
Permit Application the unit received from the resin plant scrubber was believed to contain
organic compounds such as toluene, xylene, and MEK. The skimmer
removed organic contaminants, and skimmed hydrocarbons likely were
disposed of as a blended fuel. The 1996 RFA reported that SWMU 22 was
inactive. No release from the SWMU has been documented; however,
metals have been detected in area groundwater.
SMWU 23: Two Settling Inactive The two 1,000-gallon settling basins were constructed in the sanitary sewer
Basins system prior to 1980 as part of the facility wastewater treatment system.
The 1996 RFA reported that the area occupied by these units was paved.
Wastes managed at the SWMU are unknown. No release from the SWMU
has been documented; however, metals have been detected in area
groundwater.
SWMU 24: Flocculation Inactive The flocculation tank in the old paint factory building treated process waste
Tank water to remove metals. Flocculation mud and filters were disposed of off
site and contained lead until the waste generating process changed. Liquids
were directed to the onsite wastewater treatment plant. The 1996 RFA
reported that the tank was removed. No release from the SWMU has been
documented.
SWMU A: Settling Basin Inactive The settling basin in the old paint factory may have contained solvents such
as xylene, toluene, styrene, and MEK. The settling basin is part of the
sanitary sewer system but is inactive. No release from the SWMU has been
documented.
SWMU B: Storage Inactive The two 4,700-gallon storage tanks in the basement of the paint factory
Tanks for Paint Wastes were used for mixing and holding wastes associated with paint processing
and the gel-coat manufacturing process. Wastes managed in the tank were
ignitable (D001). The 1996 RFA reported that the tanks were
decommissioned. No release from the SWMU has been documented.
SWMU C: Solvent Inactive The solvent reclamation system consisted of a 2,800-gallon spent solvent
Reclamation Still tank, a 250-gallon solvent distillation unit, a 2,000-gallon dewatering tank,
two 300-gallon mixing tanks, and a 20,000-gallon storage tank. Cook
decommissioned the solvent reclamation system in 1990. No release from
the SWMU has been documented.
SWMU D: Former Drum Inactive The two 25- by 100-foot blacktopped areas may have stored more than
Storage Areas 3,000 stacked drums of wastes containing MEK, ethylbenzene, xylene, and
lead. RCRA inspection reports identified drums leaking viscous materials
in this area; however, no evidence of leaks was observed during the visual
site inspection. Storage occurred from 1980 until the drums were removed
in 1986. A 1987 MDNR inspection report certified closure for three interim
status storage areas, one of which was probably SWMU D. Metals and
VOCs have been detected in SWMU D soils. Metals, VOCs, semivolatile
organic compounds (SVOC), and polychlorinated biphenyls (PCB) have
been detected in groundwater at SWMU D.
SWMU E: Former Drum Inactive The 50- by 100-foot paved area was used to store drums of unknown
Storage Area contents. A 1987 MDNR inspection report certified closure for three
interim status storage areas, one of which was probably SWMU E. No
drums currently are stored in this area. Metals have been detected in soil.
Metals, VOCs, and SVOCs have been detected in groundwater at SWMU
E.
SWMU F: Dirty Solvent Inactive The 2,000-gallon, aboveground, steel tank contained wastes believed to
Tank include MEK, ethyl acetate, and xylene. The tank has been removed.
VOCs have been detected in soil. Metals and VOCs have been detected in
groundwater at SWMU F.
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SWMU G: Mixing Vat Inactive Operations at the mixing vat in the paint factory began before 1980.
for D001 Wastes Managed wastes were ignitable (D001). No release from this SWMU has
been documented. The 1996 RFA reported that SWMU G was inactive.
SWMU H: Sludge Tank Inactive The 1,000-gallon tank contained solvent reclamation sludges and still
bottoms. The tank was contained by a concrete floor and a 2-foot concrete
dike. The 1996 RFA reported that the tank was removed. No release from
the SWMU has been documented.
SWMU I: Waste Sludge Inactive The waste sludge tank was operated prior to 1980 and was removed in
Tank 1991. The sludges may have been latex materials associated with paint
manufacturing. The tank was contained by a 5-foot concrete dike. No
release from the SWMU has been documented.
SWMU J: Former Drum Inactive The asphalt-paved, 25- by 100-foot area stored up to 356 drums of wastes
Storage Area containing lead, xylene, solvents, and styrene. When leaking drums were
discovered in 1985 or 1986, the remaining drums were removed, and the
underlying asphalt was cleaned and inspected for releases. A 1987 MDNR
inspection report certified closure for three interim status storage areas, one
of which was probably SWMU J. No releases to the environment were
noted. No drums currently are stored in this area.
SWMU K: Vat Washing Inactive The vat washing area operated prior to 1980 when it was decommissioned.
Area Wastes associated with the vat washing area were presumed to be MEK,
ethyl acetate, toluene, xylene, styrene, and other solvents used to wash the
vats. No information is available concerning the origin of the vats.
SVOCs have been detected in soil. Metals have been detected in
groundwater at SWMU K.
SWMU L: Building 57 Inactive During the demolition of Building 57, a water well, two concrete vaults,
tanks and separators and two tank cars containing sludge were discovered within the Building 57
foundation excavation. The sludge was disposed of off site as special or
hazardous waste. The vaults and tank cars were excavated and recycled off
site. The groundwater well contained 0.9 feet of free- phase hydrocarbon.
Total petroleum hydrocarbons (TPH) as motor oil and cis-1,2-
dichloroethene were detected in a groundwater sample from the well.

The following areas of concern (AOC) were identified in a visual site inspection of the Cook facility
conducted by EPA contractors in 1991 (Jacobs 1992) and in subsequent inspections and investigations
(BMcD 2002). The AOCs locations are depicted in Appendix A. AOC-1 and AOC-2 descriptions are
derived from the EPI/PA Report (Jacobs 1992), as updated by the RFA Report (MDNR 1996). AOC-3 and
AOC-4 descriptions are derived from the RFI Work Plan (BMcD 2002).

AOC Name Status Description


AOC 1: Air Emissions Inactive A pronounced organic odor noted during the visual site inspection caused
Cook and MDNR to enter into a Consent Order in 1991. The Order states
that MDNR has issued Notices of Violation to Cook regarding air
emissions that exceed odor limitations. The order stipulates that Cook
decrease its resin production in order to comply with Missouri regulations
concerning odor emission. MDNR’s 1996 RFA notes that a change in
plant production at the Cook facility reduced the organic odor.
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AOC 2: Former Paint Inactive The USTs for solvents and resins were located under Building 42 of the
Product and Gasoline Cook facility. The tanks, which were removed in 1986, consisted of one
Underground Storage gasoline tank, one 8,000-gallon product tank, and ten 10,000-gallon
Tank (UST) Area product tanks. Soil samples were collected at each tank removal location
and screened for light hydrocarbons. No light hydrocarbons were
detected in the soil samples; however, a sample collected from the Tank 3
excavation was described as containing a “weathered, medium- weight
oil.” Tank 3 was also described as having a hole in it. VOCs and SVOCs
have been detected in soil. Metals have been detected in groundwater at
AOC 2.
AOC 3: Railcar Active A supplemental site assessment revealed elevated concentrations of
Unloading Alleyway VOCs in soil and groundwater near the current maleic anhydride
unloading and polyester tank areas. VOCs have been detected in soil.
Metals and VOCs have been detected in groundwater at AOC 3.
AOC 4: PCB Inactive PCB containing material was encountered at a depth of about 3 feet
Investigation Area below ground surface (bgs) along the north side of an excavation for the
Building 80/Warehouse and Packaging Area foundations. The material
impacted with PCB was removed; however, some residual material
remained on the north end of the excavation.

The following areas were identified in supplemental and pre-construction site assessments (BMcD 2002).
All area descriptions are derived from the RFI Work Plan (BMcD 2002).

Area Name Status Description


Gasoline UST: Former Inactive The former gasoline UST was located on the south end of Building 52 on
Gasoline UST Area the west side of the site. No information was provided regarding the
removal of this UST.
GP-74 Area: Former Inactive Elevated VOC concentrations were detected in a soil sample collected
Railroad Bed North of from Boring GP-74 during the pre-construction site assessment for
Building 80 Building 80. No known historical activities are associated with this area.
Metals and SVOCs have been detected in groundwater in the GP- 74
Area.
Site Groundwater: Active As part of the RFI, Cook is investigating site-wide groundwater quality,
Facility Wide flow direction, and gradient; aquifer properties; and potential off-site
Investigation contaminant sources or pumping wells.

The Cook facility is located about 0.75 miles west of the river and within the river’s flood plain. The
Missouri River is classified by the State of Missouri as a Class P river at this point and is protected for
irrigation, livestock and wildlife watering, warm water aquatic life, boating and canoeing, drinking water
supply, and industrial use. At the Cook facility, surface water from Jasper Street between 14th and 15th
Streets drains to the North Kansas City storm water sewer system. Surface water from Jasper and Knox
Streets and from sumps and settling basins are directed to the Cook wastewater treatment system before
discharge, under a National Pollutant Discharge Elimination System (NPDES) permit, to the North Kansas
City storm water sewer system (Jacobs 1992).

The Cook facility is underlain by about 100 feet of alluvial sediment deposited during horizontal migration
of the Missouri River. The alluvium, which consists of sandy clay, silty sand, and gravel, is underlain by the
Bronson Subgroup of the lower Kansas City Group, which consists of limestone and shale. Groundwater
beneath the site is encountered at about 25 feet bgs and is present in the both the alluvium and the limestone
bedrock. Water in North Kansas City is obtained from the alluvial aquifer or the Missouri River, because the
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water from the limestone aquifer is saline. Groundwater flow direction fluctuates, but eventually discharges
to the Missouri River (Jacobs 1992).

Two wells on the Cook property provided water for industrial processes until 1992, when Cook began using
city water for most industrial and non-industrial uses (Jacobs 1992). Currently, one production well and 12
monitoring wells are present on the Cook property (Cook 2003). PW-1 provides non-contact cooling water
for facility processes. In support of the 1992 EPI/PA, MDNR conducted a search of registered groundwater
wells and drinking water intakes in the vicinity of the Cook facility. According to the search, the City of
North Kansas City, Missouri, maintained five deep water supply wells about 0.75 mile northwest of the Cook
facility. The City of Kansas City, Missouri, obtained 90 to 95 percent of its water from a Missouri River
intake located about 5 miles upstream of the Cook facility, but also maintained seven wells within 0.5 mile
of the river intake. The City of Kansas City, Kansas, obtained its water from a Missouri River intake located
about 6 miles upstream of the Cook facility. The City of Gladstone, Missouri, maintained five drinking
water wells about 1.75 miles northwest of the facility. No domestic or school wells were identified within 4
miles of the Cook facility (Jacobs 1992). A recent MDNR search for registered groundwater wells within
one mile of the Cook facility produced only one drinking water well–a City of North Kansas City, Missouri
drinking water well located at 2010 Howell (MDNR 2003). However, this search was conducted on the
DGLS database which does not include wells installed before 1989. A door to door survey should be
conducted to ensure there are no private drinking water wells in the area.

BACKGROUND

Definition of Environmental Indicators (for the RCRA Corrective Action)

Environmental Indicators (EI) are measures being used by the RCRA Corrective Action program to go
beyond programmatic activity measures (e.g., reports received and approved, etc.) to track changes in the
quality of the environment. The two EI developed to-date indicate the quality of the environment in relation
to current human exposures to contamination and the migration of contaminated groundwater. An EI for
non-human (ecological) receptors is intended to be developed in the future.

Definition of “Current Human Exposures Under Control” EI

A positive “Current Human Exposures Under Control” EI determination (“YE” status code) indicates that
there are no “unacceptable” human exposures to “contamination” (i.e., contaminants in concentrations in
excess of appropriate risk-based levels) that can be reasonably expected under current land- and
groundwater-use conditions (for all “contamination” subject to RCRA corrective action at or from the
identified facility (i.e., site-wide)).

Relationship of EI to Final Remedies

While Final remedies remain the long-term objective of the RCRA Corrective Action program the EI are
near-term objectives which are currently being used as Program measures for the Government Performance
and Results Act of 1993, GPRA). The “Current Human Exposures Under Control” EI are for reasonably
expected human exposures under current land- and groundwater-use conditions ONLY, and do not consider
potential future land- or groundwater-use conditions or ecological receptors. The RCRA Corrective Action
program’s overall mission to protect human health and the environment requires that Final remedies address
these issues (i.e., potential future human exposure scenarios, future land and groundwater uses, and
ecological receptors).
Cook Composites and Polymers - Current Human Exposures Under Control
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Duration / Applicability of EI Determinations

EI Determinations status codes should remain in RCRA Info national database ONLY as long as they remain
true (i.e., RCRA Info status codes must be changed when the regulatory authorities become aware of
contrary information).

2. Are groundwater, soil, surface water, sediments, or air media known or reasonably suspected to be
“contaminated”1 above appropriately protective risk-based “levels” (applicable promulgated
standards, as well as other appropriate standards, guidelines, guidance, or criteria [e.g., Maximum
Contaminant Levels (MCLs), the maximum permissible level of a contaminant in water delivered to
any user of a public water system under the Safe Drinking Water Act] from releases subject to RCRA
Corrective Action (from SWMUs, RUs or AOCs)?

Media Yes No ? Rationale/Key Contaminants


Groundwater X See description below.
Air (indoors) 2 X See description below.
Surface Soil X See description below. Deleted:
(e.g., <2 ft)
Surface Water X See description below.
Sediment X See description below.
Subsurf. Soil X See description below.
(e.g., >2 ft) Deleted:
Air (outdoors) X See description below.

_____ If no (for all media) - skip to #6, and enter “YE,” status code after providing or citing appropriate
“levels,” and referencing sufficient supporting documentation demonstrating that these “levels” are
not exceeded.

X If yes (for any media) - continue after identifying key contaminants in each
“contaminated” medium, citing appropriate “levels” (or provide an explanation for the
determination that the medium could pose an unacceptable risk), and referencing
supporting documentation.

_____ If unknown (for any media) - skip to #6 and enter “IN” status code.

For each media at the Cook facility, the following rationale and contaminants were
considered.

Soil (surface and subsurface).

In March 1996, MDNR collected soil samples in support of an RFA sampling investigation of the following
areas: SWMU-2, SWMU-18, SWMU-E, and SWMU-K. At SWMU-2, surface and subsurface soil samples
were collected and analyzed for VOCs and total lead. No VOCs were detected; however, lead in the surface
soil sample was detected at 2,500 mg/kg, a concentration that exceeds the Cleanup Levels for Missouri
(CALM ) Tier I Scenario A for residential soil (260 mg/kg) and CALM Tier I Scenario C for industrial soils
(660 mg/kg) (MDNR 2001). A surface soil sample was collected at SWMU-18 and analyzed for VOCs;
however, none were detected. A surface soil sample (3’ bgs) was collected at SWMU-E and analyzed for
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VOCs, SVOCs, and total lead. No VOCs were detected; however, lead and multiple SVOCs were detected.
2,4-dinitrotoluene (.36 mg/kg) and pentachlorophenol (1.9 mg/kg) exceeded CLEACH (.0007 mg/kg and .07
mg/kg) values. A surface soil sample was collected at SWMU-K and analyzed for VOCs and SVOCs. No
VOCs were detected (although detection limits were elevated), and the only SVOC detected (2-
methylnapthalene-400 mg/kg) was below EPA Region 3 RBCs for residential soils (1600 mg/kg) (MDNR
1996).

In 2001 and 2002, Cook conducted demolition and construction activities for the expansion of their facilities.
Two rounds of direct-push soil borings were installed at a total of 74 locations to characterize the subsurface
before excavation and construction. These sampling events identified two main areas of VOC
contamination: the area near the railroad tracks and adjacent to Building 57, and the area along the existing
north-south retaining wall running parallel to the former Jasper Street. Some contaminated soil was
excavated when the thermal oxidizer foundation, Buildings 57 and 24, and all associated structures and
foundations were removed. Additional excavation work was conducted for the utility conduits, storm sewer
lines, and foundations of the new Building 80 Warehouse and Packaging Area. During excavation, a water
well, two concrete vaults containing a black sludge material, two tank cars with paint wastes, and materials
impacted with PCBs were discovered. These materials were excavated, segregated, and characterized for
disposal offsite. A total of 69 confirmation samples were collected from the excavations. Of the
confirmation samples, 17 contained VOC concentrations that exceeded screening criteria for residential soils.
Compounds exceeding EPA Region IX Residential PRGs or CALM A levels included ethylbenzene, 1,2,4-
trimethylbenzene, n-propylbenzene, styrene, 1,3,5- trimethylbenzene, total xylenes, and Aroclor 1254.
Compounds exceeding leaching criteria include benzene, toluene, xylenes, ethylbenzene, styrene, and
methylene chloride (BMcD 2003).

The first two phases of RFI field activities were conducted at the Cook facility during the fourth quarter of
2002 and the first quarter of 2003. The first phase of RFI field activities consisted of 64 soil samples
collected from 41 direct push borings. A second phase of field activities, based on the results of the first
phase, consisted of 15 soil samples collected from 10 direct-push borings. Selected soil samples were
submitted for analysis of VOCs, SVOCs, PCBs, and metals. Soil samples were also collected during the
installation of monitoring wells MW-6 (SWMU E, site perimeter), MW-11 (site perimeter), and MW-12 (site
perimeter). Selected soil samples were submitted for analysis of VOCs, SVOCs, and metals (Cook 2003).
Contaminant concentrations that exceeded EPA Region 9 PRGs for soil or MDNR CALM A levels in
surface and subsurface soil samples collected during Phase 1 and 2 of the RFI are summarized in Tables 1
and 2, respectively. Arsenic was detected in surface soil at a concentration that exceeded CALM levels;
however, the concentration was below background levels and is not included in Table 1.
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Table 1. Compounds Detected in Surface Soil (<2’ bgs) at Concentrations


Exceeding CALM During Phase 1 and Phase 2 of the RFI

Constituent Maximum Depth Well or Date MDNR MDNR MDNR


Concentration (ft bgs) Boring CALM A CALM C CLEACH
Metals (mg/kg)
Lead 2490 .5-1.5 SWMU D 2/20/2003 260 660 -
Cadmium 106 .5-1.5 SWMU D 2/20/2003 110 380 11
Chromium 76.4 1-2 SWMU 2 8/27/2002 2100 4500 38
Volatile Organic Compounds (mg/kg)
Ethylbenzene 6000 .5-1.5 SWMU D 2/20/2003 400 400 32
Styrene 670 .5-1.5 SWMU D 2/20/2003 1500 1500 9.4
Semivolatile Organic Compounds (mg/kg)
Benzo(a)anthracene 69 1-2 SWMU D 2/20/2003 1 4 .2
Benzo(b)fluoranthene 48 1-2 SWMU D 2/20/2003 0.9 4 .6
Benzo(k)fluoranthene 67 1-2 SWMU D 2/20/2003 8 32 .6
Benzo(a)pyrene 58 1-2 SWMU D 2/20/2003 .2 .6 24
Dibenz(a,h)anthracene 11 1-2 SWMU D 2/20/2003 .2 .6 2
Indeno(1,2,3-cd)pyrene 19 1-2 SWMU D 2/20/2003 3 11 1.8
Polychlorinated Biphenyls (mg/kg)
Arochlor 1254 0.71 .5-1.5 SWMU D 2/20/2003 .6 2.5 18

Table 2. Compounds Detected in Subsurface Soil (>2’ bgs) at Concentrations


Exceeding CALM During Phase 1 and Phase 2 of the RFI

Constituent Maximum Depth Well or Date MDNR MDNR CALM


Concentration (ft bgs) Boring CALM A CALM C CLEACH
Metals (mg/kg)
Lead 2,490 3-4 SWMU D 2/20/2003 260 660 -
Selenium 16.1 2-3 SWMU E 2/20/2003 300 970 4.3
Chromium 124 3-4 SWMU D 2/20/2003 2100 4500 38
Volatile Organic Compounds (mg/kg)
Benzene 1.2 4-5 SWMU D 9/4/2002 6 13 .05
Ethylbenzene 410 11-12 SWMU F 8/30/2003 400 400 32
Methylene Chloride 1 3-4 SWMU K 8/29/2002 51 150 .02
Styrene 170 2.5-3.5 SWMU 2 8/27/2002 1500 1500 9.4
Tetrachloroethene 2.6 2.5-3.5 SWMU 2 8/26/2003 40 120 .1
Xylenes 3,400 11-12 SWMU F 8/30/2003 418 418 16
Semivolatile Organic Compounds (mg/kg)
Naphthalene 77 3-4 SWMU K 8/29/2002 120 240 24

In subsurface soils from depths exceeding 2 feet bgs, lead, ethylbenzene and total xylenes exceeded MDNR
CALM A and CALM C. Selenium, chromium, benzene, methylene chloride, styrene, tetrachloroethene, and
naphthalene exceeded leaching criteria (Cook 2003). These contaminated soils could act as a continuing
source of groundwater contamination at the Cook facility.
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Groundwater. In March 1996, MDNR collected groundwater samples from monitoring wells PW-1 and
PW-2 in support of an RFA sampling investigation. The samples were analyzed for total lead and VOCs. In
PW-1, cis-1,2-dichloroethene (DCE) was detected at concentrations below its EPA MCL or MDNR target
groundwater concentrations (GTARC). In PW-2 groundwater, lead, cis-1,2-DCE, and benzene were
detected at concentrations exceeding their EPA MCLs or MDNR GTARCs (MDNR 1996). PW-2 has
recently been abandoned in accordance with state requirements. PW-1 is still being operated but it is used
for non-contact cooling water only.

In 2001 and 2002, the thermal oxidizer foundation and Buildings 57 and 24 were excavated. Additional
excavation work was conducted for the utility conduits, storm sewer lines, and foundations of the new
Building 80 Warehouse. A water well was discovered during the excavation, and a groundwater sample was
collected from the well during January 2002. The groundwater sample was analyzed for VOCs, PCBs, and
TPH. The two compounds identified in groundwater, cis-1,2-DCE and motor oil, were below EPA MCLs
(or Region 9 PRGs) and MDNR CALM GTARCs (BMcD 2003).

Additional groundwater samples were collected in the first two phases of RFI field activities during the
fourth quarter of 2002 and the first quarter of 2003. During the first phase of RFI field activities, 41 direct
push borings were installed and 12 groundwater samples were collected. During the second phase of field
activities, which was based on the results of the first phase, 10 direct-push borings were installed and 3
groundwater samples were collected. In addition, 10 new monitoring wells were installed, and groundwater
samples were collected from a total of 14 wells on site. Groundwater samples were analyzed for metals,
VOCs, SVOCs, and PCBs, and the results were compared to MDNR GTARCs and EPA MCLs (or EPA
Region 9 PRGs for tap water where no MCLs were available) (EPA 2002a, EPA 2002b, MDNR 2001). Both
unfiltered (total metal) and filtered (dissolved metal) groundwater samples are analyzed for metals. In
general, unfiltered samples have higher concentrations of metals because of the contribution of metal in
suspended sediment. The RFI Phase 1 and 2 groundwater investigation results are summarized in Table 3.
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Table 3. Compounds Detected in Groundwater at Concentrations Exceeding MCLs


or GTARCs During Phase 1 and Phase 2 of the RFI

Constituent Maximum Well or Boring Date EPA MDNR


Concentration MCL GTARC
Metals, Filtered (µg/l)
Arsenic 256 MW-9 3/6/2003 50 50
Barium 2,310 MW-10 3/6/2003 2,000 2,000
Manganese2 3,180 MW-10 3/6/2003 880 50
Selenium 71.1 SE-D03 2/20/2003 50 50
Metals, Unfiltered (µg/l)
Arsenic 390 MW-9 3/6/2003 50 50
Barium 2,930 MW-10 3/6/2003 2,000 2,000
Chromium 183 AOC 3 9/4/2002 100 100
Lead1 173 MW-3 3/6/2003 15 15
Manganese2 4,640 MW-9 3/6/2003 880 50
Selenium 55.5 SD-D02 9/4/2002 50 50
Volatile Organic Compounds (µg/l)
Acetone2 57,000 MW-10 3/6/2003 610 NA
Benzene 74 MW-12 3/6/2003 5 5
cis-1,2-Dichloroethene 64 SE-D03 2/20/2003 70 70
Ethylbenzene 24,000 MW-10 3/6/2003 700 700
Styrene 140 MW-10 3/6/2003 100 100
Toluene 280 MW-10 3/6/2003 1000 150
1,1,2,2-Tetrachloroethane2 10 Bldg 57 Well 4/8/2003 0.055 0.3
Vinyl Chloride 3.8 MW-5 3/6/2003 2 2
Xylene (total) 35,000 MW-10 8/30/2002 10,000 320
Semivolatile Organic Compounds (µg/l)
Naphthalene 10 GP-74–D01 9/3/2002 6.2 100
Pentachlorophenol 2,900 SE-D02 8/26/2002 1 1

Notes:
1
No MCL is available; EPA action level is provided.
2
No MCL is available; EPA Region 9 PRG for tap water is provided.
EPA U.S. Environmental Protection Agency
GTARC Target groundwater concentration
MCL Maximum contaminant level
MDNR Missouri Department of Natural Resources
NA Not available
PRG Preliminary remediation goal
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Surface Water and Sediment. Surface water and sediment sampling has not been conducted by the facility,
and neither is currently scheduled to be conducted as part of the RFI (BMcD 2002). Storm water runoff
from the Cook facility is managed by a system of sumps, drains, and settling ponds (Jacobs 1992) and storm
flows are not expected to travel directly to surface water; however, contaminated groundwater could
potentially migrate from the Cook facility to the Missouri River. During the RFI, groundwater samples were
collected from newly-installed, perimeter monitoring wells. (Cook 2003). No contaminants exceeding EPA
MCLs or MDNR GTARCs were detected in the groundwater samples from MWs 6 and 11. In the
groundwater sample collected from MW-3, concentrations of unfiltered arsenic, chromium, and lead,
exceeded screening criteria and in the groundwater sample collected from MW-4, concentrations of
unfiltered arsenic, and lead, also exceeded screening criteria. Neither of these samples had exceedances in
the filtered sample. In the groundwater sample collected from MW-5, concentrations vinyl chloride
exceeded screening criteria and in the groundwater sample collected from MW-12, concentrations of
benzene, and unfiltered arsenic and lead exceeded screening criteria. These results are summarized in Table
3.

Considering the distance to the Missouri river, the relatively low groundwater contaminant concentrations,
the likely volatilization of benzene in surface water, the contribution of suspended sediment to unfiltered
metals concentrations, and the large volume of water in the Missouri River, contamination from the Cook
facility is not expected to impact significantly the Missouri River, which is located about 0.75 mile
downgradient.

Indoor Air. Because of the presence of VOCs in shallow groundwater and surface soil at the facility, indoor
air may be contaminated with organic vapors. However, it is not anticipated that contamination due to
volatilization from contaminated soil and groundwater is significant when compared to the fugitive vapors
generated by the production processes at the facility. Vapors from contaminated soil and groundwater may
enter facility buildings through cracks in the foundation or through underground plumbing or electrical
conduits. No indoor air sampling has been conducted at the Cook facility, and no air sampling is scheduled
during the RFI (BMcD 2002). However, EPA guidance can be used to determine if significant indoor air
contamination is likely at the facility (EPA 2002a), and the Johnson-Ettinger model can be used to estimate
indoor air concentrations at appropriate indoor locations that meet the screening criteria (EPA 2002a). The
results of the screening and models are provided in Appendix B.

The first tier of EPA’s indoor air screening consists of two criteria that are met at the Cook facility. First,
environmental media at the site must be contaminated by constituents that are sufficiently volatile and toxic
as specified in Table 1 of the EPA indoor air screening guidance (EPA 2002a). Groundwater and soil at the
facility are contaminated with several constituents that meet this standard. In unsaturated soil samples
collected from the Cook facility, benzene, benzo(b)fluoranthene, ethylbenzene, methylene chloride,
naphthalene, PCE, styrene, and xylenes exceeded EPA PRGs or MDNR CALM values and were sufficiently
toxic and/or volatile. In groundwater samples collected from the Cook facility, benzene, cis-1,2-
dichloroethene, naphthalene, 1,1,2,2-tetrachloroethane, and xylenes exceeded EPA MCLs, PRGs or MDNR
CALM GTARC values and were sufficiently toxic and volatile. Second, the subsurface contamination must
be present near inhabited buildings. Although no inhabited buildings are located on the SWMUs and AOCs
with sufficiently toxic and volatile subsurface contamination, nearly all of these SWMUs and AOCs are
located adjacent to or within 100 feet of active facility buildings (see Figure 2, Appendix A). Because of the
proximity of subsurface contamination to inhabited buildings, it is reasonable to assume that contamination
may migrate from the contaminated SWMUs and AOCs beneath the inhabited buildings. An exception to
this is the new processing building 80 recently completed. Because of the identified contamination during
the building construction, a vapor barrier was incorporated into the building plan to prevent indoor air
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contamination from contaminated soil and groundwater. To proceed to the next level of EPA’s indoor air
screening, there must be no evidence to suggest that immediate action is warranted to mitigate current risks.
Because no odors, physiological effects, wet basements, or other short-term safety concerns were identified
in the record, indoor air screening for the Cook facility proceeds to the second level.

The second tier of EPA's indoor air screening compares the concentrations of contaminants to screening
levels for indoor air, soil gas, and groundwater. Indoor air and soil gas data are not available for the Cook
facility, and EPA’s guidance currently does not recommend using bulk soil analyses to assess the
completeness of the vapor intrusion pathway under Tier 2 (EPA 2002a). However, concentrations of VOCs
in groundwater at the Cook facility are sufficient to pass this level of screening. EPA’s groundwater
screening levels are based on concentrations needed to generate vapors in indoor air at levels that would
exceed risk levels for ambient air. Table 4 shows the maximum concentrations of select VOCs and SVOCs
in groundwater, compared to the Tier 2 screening concentrations. The vapor attenuation factor of 7x10-4 was
estimated based on depth to groundwater, about 25 feet (7.6 meters) bgs, and the type of soil at the site,
considered sand for the purpose of this model (Jacobs 1992). Based on this level of screening, benzene, cis-
1,2-DCE, and 1,1,2,2-tetrachloroethane may cause contamination of indoor air and should be included in any
modeling.

Table 4. Indoor Air Screening, Tiers 2 and 3

Constituent Maximum Tier 2 Location Date Incremental Hazard


Concentration Screening Risk Quotient
(µg/L) Level (µg/L) (carcinogen) (noncarcinogen)
Benzene 78 5 MW-2 3/12/1996 7.6 x 10-7 NA
cis-1,2- 100 300 MW-2 3/12/1996 NM NM
Dichloroethene
Naphthalene 10 220 GP-74 9/3/2002 NM NM
Area
1,1,2,2- 10 4.2 Bldg. 57 4/8/2003 3.8 x 10-8 NA
Tetrachloroethane Well
Xylenes 1,100 47,000 SWMU F 8/30/2002 NM NM
Notes:
NA Not applicable
NM Not modeled
Sources: Cook 2003, EPA 2002a, MDNR 1996

The third and final tier of the EPA's indoor air screening specifies the use of a model to estimate the risk
generated by organic vapors in indoor air. Based on the results of Johnson-Ettinger models, volatilization of
organic constituents from groundwater to indoor air does not cause a risk (see Appendix B). Table 4 shows
the results of the Johnson-Ettinger models. For both compounds modeled, the incremental risk is less than 1
x 10-6, indicating that this component of risk is not significant.

Although EPA’s guidance currently does not recommend using bulk soil analyses to assess the completeness
of the vapor intrusion pathway under Tier 2 (EPA 2002a), VOC concentrations in unsaturated soil samples
that exceeded EPA PRGs or MDNR CIDI values were modeled to determine whether unsaturated soil is a
potential threat to indoor air. Based on the results of Johnson-Ettinger models, volatilization of organic
constituents from unsaturated soil to indoor air does not cause a risk (see Appendix B).
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Outdoor Air. The potential risks and hazards from inhalation of outdoor air are anticipated to be less than
those of indoor air due to dispersion and unconfined space. Because most of the facility is covered with
buildings and pavement, potential contamination of air via entrainment of contaminated soil particulates
appears negligible.

3. Are there complete pathways between “contamination” and human receptors such that exposures
can be reasonably expected under the current (land- and groundwater-use) conditions?

Summary Exposure Pathway Evaluation Table


Potential Human Receptors (Under Current Conditions)
“Contaminated” Residents Workers Day- Construction Trespasser Recreation Food3
Media Care s
Groundwater NO YES NO NO NO NO NO
Air (indoors) --- --- --- --- --- --- ---
Soil (surface, e.g., NO YES NO YES NO NO NO
<2 ft)
Surface Water --- --- --- --- --- --- ---
Sediment - - - - - - - - - - - - - - - - - - ---
Soil (subsurface e.g., NO NO NO YES NO NO NO
>2 ft)
Air (outdoors) --- --- --- --- --- --- ---

Instructions for Summary Exposure Pathway Evaluation Table:

1. Strike-out specific Media including Human Receptors’ spaces for Media which are not “contaminated”)
as identified in #2 above.

2. enter “yes” or “no” for potential “completeness” under each “Contaminated” Media -- Human Receptor
combination (Pathway).

Note: In order to focus the evaluation to the most probable combinations some potential “Contaminated”
Media - Human Receptor combinations (Pathways) do not have check spaces (“___”). While these
combinations may not be probable in most situations they may be possible in some settings and should be
added as necessary.

_____If no (pathways are not complete for any contaminated media-receptor combination) - skip to #6, and
enter ”YE” status code, after explaining and/or referencing condition(s) in-place, whether natural or
man-made, preventing a complete exposure pathway from each contaminated medium (e.g., use
optional Pathway Evaluation Work Sheet to analyze major pathways).

X If yes (pathways are complete for any “Contaminated” Media - Human Receptor combination) -
continue after providing supporting explanation.

_____If unknown (for any “Contaminated” Media - Human Receptor combination) - skip to #6 and enter
“IN” status code
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Rationale and Reference(s):

Resident

Groundwater = Incomplete Pathway. The Cook facility is in an industrial area, and land use within a 1-mile
radius of the facility is dominated by facilities including Seeburg Warehouse, Fabri-Quilt, Inc., Harrisonville
Harness, D&O Distributing, Dean Rubber Company, Pella Windows and Doors (Warehouse and Service),
Stationers Distributing Company, and the Burlington Northern Railroad Hub Center (BMcD 2002). The
nearest residential property is located beyond the extent of known groundwater contamination from the Cook
facility. The nearest registered drinking water production well to the Cook facility is located at 2010 Howell
(MDNR 2003). The well is about 0.75 mile to the north of the Cook facility and is beyond the extent of
known groundwater contamination.

Surface Soil = Incomplete Pathway. The nearest residential property is located beyond the extent of known
surface soil contamination from the Cook facility. The surface soil pathway is incomplete because the main
plant area is almost entirely paved and fenced. SWMU 2, the settling basin east of the main plant area, is
secured by a separate fence (Jacobs 1992).

Subsurface Soil = Incomplete Pathway. The nearest residential property is located beyond the extent of
known subsurface soil contamination from the Cook facility. The subsurface soil pathway is incomplete
because the main plant area is almost entirely paved and fenced. SWMU 2, the settling basin east of the
main plant area, is secured by a separate fence (Jacobs 1992).

Worker

Groundwater = Complete Pathway. Groundwater potentially provides a complete pathway to workers who
sample or maintain monitoring wells at the Cook facility.

Surface Soil = Complete Pathway. Surface soil potentially provides a complete pathway to workers who
perform duties in contact with bare earth. However, the main plant area is almost entirely paved or covered
with buildings and other structures (Jacobs 1992).

Subsurface Soil = Incomplete Pathway. Workers would not be expected to penetrate the soil below 2 feet
bgs. Additionally, the subsurface soil pathway is incomplete because the main plant area is almost entirely
paved and fenced. SWMU 2, the settling basin east of the main plant area, is secured by a separate fence
(Jacobs 1992).

Day Care

Groundwater = Incomplete Pathway. The nearest day care center to the Cook facility is Kids First, located
about 0.9 mile to the southeast. The nearest schools to the Cook facility are Sanford-Brown College, located
about 0.7 mile to the north, and the North Kansas City High School, located 0.8 mile to the north
(SuperPages 2003). The day care center and schools are located beyond the extent of known groundwater
contamination. Additionally, the nearest registered drinking water production well to the Cook facility is
located at 2010 Howell, about 0.75 mile to the north (MDNR 2003), so the drinking water production well
that might contribute to the drinking water supply of the schools and daycare also is beyond the extent of
known groundwater contamination.
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Surface Soil = Incomplete Pathway. The nearest day care center and school to the Cook facility are located
about 0.9 and 0.7 mile to the north, respectively (SuperPages 2003). The day care center and schools are
located beyond the extent of known surface soil contamination.

Subsurface Soil = Incomplete Pathway. The nearest day care center and school to the Cook facility are
located about 0.9 and 0.7 mile to the north, respectively (SuperPages 2003). The day care center and schools
are located beyond the extent of known subsurface soil contamination.

Construction Worker

Groundwater = Incomplete Pathway. Construction workers likely would not encounter groundwater, even
with excavation equipment, because depths to groundwater typically exceed 10 feet below ground surface
(Jacobs 1992).

Surface Soil = Complete Pathway. Surface soil potentially provides a complete pathway to workers who
perform shallow excavations and other duties in contact with bare earth. However, the main plant area is
almost entirely paved or covered with buildings and other structures (Jacobs 1992).

Subsurface Soil = Complete Pathway. Subsurface soil potentially provides a complete pathway to workers
who perform excavations in contact with bare earth.

Trespasser

Groundwater = Incomplete Pathway. Trespassers likely would not contact groundwater at the Cook facility,
because this would require unlocking and pumping secured groundwater wells. Additionally, the Cook
facility is secured by a chain link fence and a guard house (Jacobs 1992).

Surface Soil = Incomplete Pathway. Trespassers likely would not contact significantly contaminated surface
soil, because the main plant area is almost entirely paved and fenced. SWMU 2, the settling basin east of the
main plant area, is secured by a separate fence (Jacobs 1992).

Subsurface Soil = Incomplete Pathway. Trespassers likely would not contact significantly contaminated
subsurface soil, because the main plant area is almost entirely paved and fenced. SWMU 2, the settling basin
east of the main plant area, is secured by a separate fence (Jacobs 1992).

Recreation

Groundwater = Incomplete Pathway. No recreational use of the Cook facility is anticipated. Additionally,
the groundwater pathway is incomplete because wells are secured with locks and metal protective casings.

Surface Soil = Incomplete Pathway. No recreational use of the Cook facility is anticipated. Additionally,
the surface soil pathway is incomplete because the main plant area is almost entirely paved and fenced.
SWMU 2, the settling basin east of the main plant area, is secured by a separate fence (Jacobs 1992).

Subsurface Soil = Incomplete Pathway. No recreational use of the Cook facility is anticipated, and
recreational users would not be expected to penetrate the soil below 2 feet bgs. Additionally, the subsurface
soil pathway is incomplete because the main plant area is almost entirely paved and fenced. SWMU 2, the
settling basin east of the main plant area, is secured by a separate fence (Jacobs 1992).
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Food

Groundwater = Incomplete Pathway. No food items are produced or grown in contact with groundwater
contaminated by the Cook facility. Surrounding properties are primarily industrial (BMcD 2002).

Surface Soil = Incomplete Pathway. No food items are produced or grown in contact with surface soil
contaminated by the Cook facility. Surrounding properties are primarily industrial (BMcD 2002).

Subsurface Soil=Incomplete Pathway. No food items are produced or grown in contact with subsurface soil
contaminated by the Cook facility. Surrounding properties are primarily industrial (BMcD 2002).

4. Can the exposures from any of the complete pathways identified in #3 be reasonably expected to be
“significant”4 (i.e., potentially “unacceptable” because exposures can be reasonably expected to be:
1) greater in magnitude (intensity, frequency and/or duration) than assumed in the derivation of the
acceptable “levels” (used to identify the “contamination”); or 2) the combination of exposure
magnitude (perhaps even though low) and contaminant concentrations (which may be substantially
above the acceptable “levels”) could result in greater than acceptable risks)?

X If no (exposures can not be reasonably expected to be significant (i.e., potentially “unacceptable”) for
any complete exposure pathway) - skip to #6 and enter “YE” status code after explaining and/or
referencing documentation justifying why the exposures (from each of the complete pathways) to
“contamination” (identified in #3) are not expected to be “significant.”

_____ If yes (exposures could be reasonably expected to be “significant” (i.e., potentially “unacceptable”)
for any complete exposure pathway) - continue after providing a description (of each potentially
“unacceptable” exposure pathway) and explaining and/or referencing documentation justifying why
the exposures (from each of the remaining complete pathways) to “contamination” (identified in #3)
are not expected to be “significant.”

_____ If unknown (for any complete pathway) - skip to #6 and enter “IN” status code

Rationale and Reference(s):

The complete exposure pathways identified above include Worker to Groundwater, Worker to Surface Soil,
Construction Worker to Surface Soil, and Construction Worker to Subsurface Soil.

Groundwater potentially provides a complete pathway to workers who sample or maintain wells at the Cook
facility. However, given facility health and safety practices and commercial worker exposure parameters,
exposures for this pathway cannot reasonably be expected to be significant. One of Cooks production wells
(PW-2) has been decommissioned, but PW-1 is still used for production water. In addition, workers may
conduct well maintenance and collect groundwater samples from the monitoring and production wells as
often as quarterly, resulting in an exposure duration of less than 20 to 25 days per year. Applicable
standards–specifically EPA MCLs and tap water PRGs–were developed for residential adults as opposed to
temporary on-site workers. The exposure duration for residential adults is up to 350 days per year for 30
years (EPA 2002b). Exposures from the completed Worker to Groundwater pathway cannot reasonably be
expected to be significant.
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Surface soil potentially provides a complete exposure pathway to workers and construction workers who
contact bare soil. However, a large portion of the facility is covered with pavement and buildings, greatly
reducing the potential for worker exposure to surface soil. Cook facility health and safety practices, and
limited worker and construction worker exposure durations, also reduce the potential for worker exposure to
surface soil. Residential PRGs for soil were developed for a residential adult with exposure up to 350 days
per year for 30 years, and industrial PRGs for soil were developed for a worker with exposure up to 250
days per year for 25 years (EPA 2002b). Considering the limited exposure of workers to surface soil, surface
soil contaminant concentrations, and worker exposure parameters, exposures from the completed Surface
Soil to Worker and Surface Soil to Construction Worker pathways cannot reasonably be expected to be
significant.

Subsurface soil potentially provides a complete exposure pathway to construction workers who contact bare
soil. Cook facility health and safety practices, and limited construction worker exposure durations, also
reduce the potential for worker exposure to surface soil. Residential PRGs for soil were developed for a
residential adult with exposure up to 350 days per year for 30 years, and industrial PRGs for soil were
developed for a worker with exposure up to 250 days per year for 25 years (EPA 2002b). Considering the
limited exposure of construction workers to subsurface soil, subsurface soil contaminant concentrations, and
worker exposure parameters, exposures from the completed Subsurface Soil to Construction Worker
pathway cannot reasonably be expected to be significant.

5. Can the “significant” exposures (identified in #4) be shown to be within acceptable limits?

_____ If yes (all “significant” exposures have been shown to be within acceptable limits) - continue and
enter “YE” after summarizing and referencing documentation justifying why all “significant”
exposures to “contamination” are within acceptable limits (e.g., a site- specific Human Health Risk
Assessment).

_____ If no (there are current exposures that can be reasonably expected to be “unacceptable”)- continue
and enter “NO” status code after providing a description of each potentially “unacceptable”
exposure.

_____ If unknown (for any potentially “unacceptable” exposure) - continue and enter “IN” status code

Rationale and Reference(s):


Cook Composites and Polymers - Current Human Exposures Under Control
Environmental Indicator (EI) RCRA Info code (CA725)
Page 21

6. Check the appropriate RCRA Info status codes for the Current Human Exposures
Under Control EI event code (CA725), and obtain Supervisor (or appropriate Manager)
signature and date on the EI determination below (and attach appropriate supporting
documentation as well as a map of the facility):

X YE - Yes, “Current Human Exposures Under Control” has been verified. Based on a review of the
information contained in this EI Determination, “Current Human Exposures” are expected to be
“Under Control” at the Cook Composites and Polymers Co. facility, EPA ID #MOD086787371,
located at 920 East 14th Avenue, Kansas City, Missouri under current and reasonably expected
conditions. This determination will be re-evaluated when the Agency/State becomes aware of
significant changes at the facility.

____ NO - “Current Human Exposures” are NOT “Under Control.”

____ IN - More information is needed to make a determination.


Cook Composites and Polymers - Current Human Exposures Under Control
Environmental Indicator (EI) RCRA Info code (CA725)
Page 22

Completed by Original signed by Date __9/29/03_____


Patrick Quinn
Project Manager, Corrective Action Unit
Hazardous Waste Program
Missouri Department of Natural Resources

Supervisor Original signed by Date _____9/29/03____


Richard A. Nussbaum, P.E., R.G.
Chief, Corrective Action Unit
Hazardous Waste Program
Missouri Department of Natural Resources

Locations where References may be found:

Missouri Department of Natural Resources


1738 E. Elm Street
Jefferson City, Missouri 65101

Contact telephone and e-mail numbers

Patrick Quinn
(573) 751-3553
nrquinp@mail.dnr.state.mo.us

final Note: The Human Exposures EI is a Qualitative Screening of exposures and the
determinations within this document should not be used as the sole basis for restricting
the scope of more detailed (e.g., site-specific) assessments of risk.
Cook Composites and Polymers - Current Human Exposures Under Control
Environmental Indicator (EI) RCRA Info code (CA725)
Page 23

REFERENCES

Burns & McDonnell Engineering Company, Inc. (BMcD). 2003. Demolition and
Construction Excavation Activities Summary Report, Cook Composites and Polymers Co.,
North Kansas City Facility. Prepared for Missouri Department of Natural Resources
(MDNR). July 10.

BMcD. 2002. RCRA Facility Investigation Work Plan, Cook Composites and Polymers Co.,
920 East 14th Avenue, North Kansas City, Missouri. Prepared for U.S. Environmental
Protection Agency (EPA) Region VII. July.

Cook Composites and Polymers. 2003. Quarterly Progress Report – First Quarter 2003,
Cook Composites and Polymers Co., North Kansas City Facility. From M. Gromacki, Cook
Composites and Polymers Co., to R.K. Morrison, MDNR. May 27.

EPA. 2002a. Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from
Groundwater and Soils. November 29.

EPA. 2002b. Region 9 Preliminary Remediation Goals (PRG) Table Update. October 1.

EPA. 2002c. National Primary Drinking Water Standards. July.


Jacobs Engineering Group, Inc. (Jacobs). 1992. Volume I Environmental Priorities
Initiative/Preliminary Assessment Report for Cook Paint and Varnish, North Kansas City,
Missouri, MOD086787371. Prepared for EPA Region VII. September.

MDNR. 2003. Well Search Within a One-Mile Radius of 50N 33W Section 23. From
Sharon Beistel, MDNR. To Jessica Kidwell, Tetra Tech EMI. August 15.

MDNR, Hazardous Waste Program. 2001. Cleanup Levels for Missouri, Revised Table B1:
Soil and Groundwater Target Concentrations. January.

MDNR. 1996. Final Resource Conservation and Recovery Act (RCRA) Facility Assessment
Report Addendum, Cook Composites and Polymers, Kansas City, Missouri, EPA ID No.
MOD086787371. September.

Superpages. 2003. Search for Kansas City, Missouri, Schools and Daycare Centers within 1
Mile of 920 East 14th Avenue, Kansas City, Missouri. Available at html:
http://yp108.superpages.com. August 27.
Cook Composites and Polymers - Current Human Exposures Under Control
Environmental Indicator (EI) RCRA Info code (CA725)
Page 24

APPENDIX A

FIGURES
Cook Composites and Polymers - Current Human Exposures Under Control
Environmental Indicator (EI) RCRA Info code (CA725)
Page 25

APPENDIX B

VAPOR INTRUSION PATHWAY SUMMARY PAGE


Cook Composites and Polymers - Current Human Exposures Under Control
Environmental Indicator (EI) RCRA Info code (CA725)
Page 26

VAPOR INTRUSION PATHWAY SUMMARY PAGE

Facility Name: Cook Composites and Polymers Co.


Facility Address: 920 East 14th Avenue, P.O. Box 419389, Kansas City, Missouri 64141-
6389

Primary Screening Summary

Q1: Constituents of concern Identified?


X Yes
No (If NO, skip to the conclusion section below and check NO to indicate the pathway is
incomplete.)

Q2: Currently inhabited buildings near subsurface contamination?


X Yes
No

Areas of future concern near subsurface contamination?


X Yes
No (If NO, skip to the conclusion section below and check NO to indicate the pathway is
incomplete.)

Q3: Immediate Actions Warranted?


Yes
X No

Secondary Screening Summary

Vapor source identified:


X Groundwater
X Soil
Insufficient Data

Indoor air data available?


Yes
X No

Indoor air concentrations exceed target levels?


Yes
No
X Not applicable
Cook Composites and Polymers - Current Human Exposures Under Control
Environmental Indicator (EI) RCRA Info code (CA725)
Page 27

Subsurface data evaluation: (Underline appropriate answers below)

Medium
Groundwater YES / NO / NA / INS YES / NO / NA / INS YES / NO / INS
Soil Gas YES / NO / NA / INS YES / NO / NA / INS YES / NO / INS

Notes:

NA Not applicable
INS Insufficient data available to make a determination

Site-Specific Summary

Have the nature and extent of subsurface contamination, potential preferential pathways, and
overlaying building characteristics been adequately characterized to identify the most-likely-
to-be-impacted buildings?
X Yes
No
N/A

EPA recommends that if a model was used, it be an appropriate and applicable model that
represents the conceptual site model. If other means were used, document how you
determined the potentially most impacted areas to sample. EPA recommends that predictive
modeling can be used to support Current Human Exposures Under Control EI determinations
without confirmatory sampling to support this determination. Current Human Exposures
Under Control EI determinations are intended to reflect a reasonable conclusion by EPA or
the State that current human exposures are under control with regard to the vapor intrusion
pathway and current land use conditions. Therefore, if conducting evaluation for an EI
determination, document that the Pathway is Incomplete and/or does not pose an
unacceptable risk to human health for EI determinations.

Are you making an EI determination based on modeling and does the model prediction
indicate that determination is expected to be adequately protective to support Current Human
Exposures Under Control EI determinations?
X Yes
No
N/A

Do subslab vapor concentrations exceed target levels?


Yes
No
X N/A

Do indoor air concentrations exceed target levels?


Yes
X No
Cook Composites and Polymers - Current Human Exposures Under Control
Environmental Indicator (EI) RCRA Info code (CA725)
Page 28

Conclusion

Is there a Complete Pathway for subsurface vapor intrusion to indoor air?

Below, check the appropriate conclusion for the Subsurface Vapor to Indoor Air Pathway
evaluation and attach supporting documentation as well as a map of the facility.

X NO - The “Subsurface Vapor Intrusion to Indoor Air Pathway” has been verified to
be incomplete for the Cook Composites and Polymers Co. facility, EPA ID
#MOD086787371, located at 920 East 14th Avenue, Kansas City, Missouri.

This determination is based on a review of site information, as suggested in this guidance,


check as appropriate:

X For current and reasonably expected conditions, or Based on performance monitoring


evaluations for engineered exposure controls. This determination may be re-evaluated,
where appropriate, when the Agency/State becomes aware of any significant changes
at the facility.

YES - The “Subsurface Vapor Intrusion to Indoor Air Pathway” is Complete. Engineered
controls, avoidance actions, or removal actions taken include:

UNKNOWN - More information is needed to make a determination.

1
“Contamination” and “contaminated” describes media containing contaminants (in any
form, NAPL and/or dissolved, vapors, or solids, that are subject to RCRA) in concentrations
in excess of appropriately protective risk-based “levels” (for the media, that identify risks
within the acceptable risk range).
2
Recent evidence (from the Colorado Dept. of Public Health and Environment, and others)
suggest that unacceptable indoor air concentrations are more common in structures above
groundwater with volatile contaminants than previously believed. This is a rapidly
developing field and reviewers are encouraged to look to the latest guidance for the
appropriate methods and scale of demonstration necessary to be reasonably certain that indoor
air (in structures located above (and adjacent to) groundwater with volatile contaminants)
does not present unacceptable risks.
3
Indirect Pathway/Receptor (e.g., vegetables, fruits, crops, meat and dairy products, fish,
shellfish, etc.)
4
If there is any question on whether the identified exposures are “significant” (i.e., potentially
“unacceptable”) consult a human health Risk Assessment specialist with appropriate
education, training and experience.